United States

On September 3, 2014, the US federal banking regulators (the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of Comptroller of the Currency) announced the final adoption of the liquidity coverage ratio for large financial institutions under their supervision. The liquidity coverage ratio, or LCR, requires that covered banking organizations maintain sufficient…

On September 11, 2014, the Office of the Comptroller of the Currency (OCC) published final Guidelines setting out heightened risk management standards for large banking organizations under its jurisdiction.  The OCC had issued proposed guidelines in January 2014 for comment and made some revisions to the final version of the Guidelines in response to those…

The FINRA Board of Governors (the “Board”) met last week to discuss a number of upcoming rule proposals and initiatives, many which focus on high-frequency trading and market transparency. FINRA Chairman and CEO Rick Ketchum stated that he believes these proposals address Securities and Exchange Commission (“SEC”) Chair Mary Jo White’s call to action for…

A federal district court has handed the Commodity Futures Trading Commission (CFTC) a substantial victory, largely rejecting a legal challenge to the agency’s cross-border interpretive guidance brought by financial trade associations such as SIFMA and ISDA. The court’s Opinion means that, absent a successful appeal, the CFTC’s Guidance and its cross-border application of its Dodd-Frank…

CME Rule 575, codifying types of disruptive order entry and trading practices is effective today. Our September 8, 2014 blog post discusses the new rule and a related CME advisory.

Last week, CME’s Chief Regulatory Officer, Global Head of Enforcement and Global Head of Investigations provided an outreach webinar on the new rule hosted by…

The U.S. House of Representatives has passed H.R. 4413, a bill that would reauthorize the Commodity Futures Trading Commission (CFTC) and also make some important changes to the Commodity Exchange Act (CEA), including changing the definition of the term “swap” in a way that would benefit certain physical market participants. H.R. 4413, which currently is…

This Summer, the Securities and Exchange Commission (SEC) adopted long-awaited rules on cross-border security-based swap activities.  The SEC’s rules provide:  1) an explanation of when a cross-border transaction must be counted towards the requirement to register as a security-based swap dealer (SBSD) or major security-based swap participant (MSBSP), including transactions guaranteed by a US person…

Staff of the Commodity Futures Trading Commission (CFTC) has issued an Interpretation permitting futures commission merchants (FCMs) to deposit US customer funds margining foreign futures and options positions with UK investment firms that are licensed deposit-taking banks as bank deposits.

CFTC customer protection rules

Part 30 of the CFTC’s regulations governs the offer and sale…

During an otherwise quiet Summer at the Commodity Futures Trading Commission (CFTC), agency staff hosted a public Roundtable where commercial end-users and other market participants could comment on the CFTC’s re-proposed rules to implement the position limits and aggregation provisions of the Dodd-Frank Act.  The common theme from end-users was that the CFTC’s proposals would…