Nanette Aguirre

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EU Proposes New Rules to Manage Leverage and Derivative Exposure for Funds – Are Asset Managers Ready?

The European Systemic Risk Board (the Board) published a recommendation that the European Union should adopt rules to prevent funds from taking on excessive debt and from allocating inadequate reserves to compensate for assets that are hard to sell.  The board went so far as to suggest stronger liquidity stress tests, improved liquidity management and … Continue Reading

President Trump to Nominate CFTC Acting Head J. Christopher Giancarlo

President Trump has announced his intention to nominate Commodity Futures Trading Commission (CFTC) acting head J. Christopher Giancarlo as permanent chairman. This news is of high importance for the alternative investment community, which will be impacted by  Giancarlo’s regulatory vision for the agency and Dodd-Frank reform.  As a Republican commissioner at the agency since 2014, … Continue Reading

No Action Relief Regarding Variation Margin Rules

Yesterday, the U.S. Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) announced the issuance of a time-limited no-action letter stating that, from March 1, 2017 to September 1, 2017, DSIO will not recommend an enforcement action against a swap dealer (SD) for failure to comply with the variation margin requirements … Continue Reading

Derivatives Update: What You Should Know As We Enter 2017

This year has been full of surprises in the global markets with Brexit, the Republicans’ win of the executive branch and continuing control of the legislative branch in the U.S. and the impact of the privatization of energy markets in Mexico. In this GT Alert, we are simply going to address two critical proposals and … Continue Reading

Asset Managers and Cybersecurity Risk Management

As if 2016 wasn’t challenging enough for asset managers, the rise in Cybersecurity risk has certainly become increasingly prevalent.  As our industry continues to depend on digital platforms for real time processing from everything from data storage to clearing, asset managers must realize that the threat of a security breach is no longer just about … Continue Reading

Article 55 BRRD Can Impact Your Company

Buy side entities should carefully review such agreements as their ISDA Master Agreements, Securities Lending Agreements and Repurchase Agreements, to name a few, for any Article 55 BRRD provisions. Article 55 BRRD is the EU’s Bank Recovery and Resolution Directive (BRRD) which essentially authorizes the European government to write down and convert amounts owed by … Continue Reading

How the SEC Proposed New Derivatives Rules Affect Registered Funds and Business Development Companies

On Dec. 11, 2015, the SEC proposed new derivatives rules for registered funds and business development companies. The proposed rules set limits on portfolio exposure and the requirement that funds maintain derivative risk management programs. It is important to evaluate these proposed limits against existing “stress testing” clearing and portfolio margining models. Derivative traders have 90 … Continue Reading
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