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The CFTC, the SEC and prudential regulators in the United States have made significant progress on the detailed rules to implement the swap market reforms contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act. The principal changes are in...

On January 11, 2012, the Commodity Futures Trading Commission ("CFTC") adopted business conduct rules governing duties of swap dealers ("SDs") and major swap participants ("MSPs") to their counterparties. The rules, which address...

On January 11, 2012, the U.S. Commodity Futures Trading Commission (the "CFTC") approved final rules (the "Final Rules") establishing a registration process for swap dealers ("SDs") and major swap participants ("MSPs" and,...

In the past year, the CFTC, the SEC and prudential regulators in the United States have produced drafts of many of the detailed rules to implement the swap market reforms contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act. Most of the...

On September 8, 2011, the U.S. Commodity Futures Trading Commission (the "CFTC") issued two proposed rules addressing the timetable for implementation of new regulatory requirements for swaps under the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank")....

On Monday, August 1, 2011, the Commodity Futures Trading Commission ("CFTC") and the Securities Exchange Commission ("SEC", and together with the CFTC, the "Commissions") jointly held a public roundtable discussion on international...

The reforms of over-the-counter (OTC) derivatives markets threaten the ability of international banking groups to centralise the risk management of their cross-border derivatives business. The resulting more regionalised booking models are likely to reduce client...

In September 2009, the leaders of the G-20 stated that "All standardized OTC derivatives contracts should be traded on exchanges or electronic trading platforms, where appropriate, and cleared through central counterparties by end-2012 at the latest." In the United...

The Commodity Futures Trading Commission (the "CFTC") has proposed rules that would remove the exemptions that many US fund managers and non US fund managers of US funds currently rely on to avoid the need to register as commodity pool operators ("CPOs")...

Following the enactment of the Dodd-Frank Act, the regulators have proposed multiple regulations governing swaps. The proposal stage for the regulations is now largely complete. We have therefore drafted a description of swap trading restrictions and sales compliance...