Continue Reading Commodity Futures Trading Commission Issues Time-Limited Relief from CFTC Rule 1.56

News & Commentary on Financial Regulatory and Compliance Matters
The Commodity Futures Trading Commission (CFTC) issued Letter No. 20-28 on Sept. 15, 2020. Letter 20-28 addresses issues of relevance both for futures commission merchants (FCMs) as well as asset
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Continue Reading Commodity Futures Trading Commission Issues Time-Limited Relief from CFTC Rule 1.56
On June 25, 2020, the five commissioners of the Commodity Futures Trading Commission (CFTC), by a vote of three-to-two, withdrew proposed Regulation Automated Trading (Reg. AT), and by a vote…
Continue Reading CFTC Cancels and Replaces Proposed Regulation AT
On May 28, 2020, the Commodity Futures Trading Commission (CFTC or the Commission) proposed a rule (the 2020 Proposal) broadening the exemption under which non-U.S. commodity pool operators (CPOs)
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Continue Reading CFTC Proposes Expanding Exemption for Non-U.S. Commodity Pool Operators
On Oct. 11, 2019, the Financial Crimes Enforcement Network (FinCEN), the U.S. Commodity Futures Trading Commission (CFTC), and the U.S. Securities and Exchange Commission (SEC), published a Joint Statement on …
Continue Reading CFTC, FinCEN and SEC Issue Joint Statement Reminding Persons in Digital Assets Space of Obligations Under Bank Secrecy Act
Departing from its historical practice but following the approach taken by the SEC and FINRA, the Commodity Futures Trading Commission (CFTC) on Feb. 12, 2019, announced its first release of …
Continue Reading CFTC and NFA Commodities Regulatory Update
The CFTC has asserted that Bitcoin is, and other virtual currencies may be, commodities under the Commodity Exchange Act. As such, pursuant to Section 2(c)(2)(D) of such Act, “off exchange”…
Continue Reading Financing Bitcoin: The Problem of Actual Delivery
The rise of blockchain technology ventures raising money preternaturally through initial coin offerings and token generation events (collectively, ICOs) is a capital formation disruptor, one which has and will continue…
Continue Reading Regulators Weigh in on Digital Assets, Tokens, Securities, and Derivative Instruments Used in ICOs
Shareholders Carl A. Fornaris and William B. Mack of global law firm Greenberg Traurig, LLP will be participating at the Financial Markets Association’s 2017 Treasury and Capital Markets Legal and…
Continue Reading Greenberg Traurig’s Carl Fornaris and William Mack Participate at FMA’s Legal and Legislative Issues Conference
On Sept. 25, 2017, the Program on Corporate Compliance and Enforcement and the Institute for Corporate Governance and Finance at New York University School of Law hosted a policy speech
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Continue Reading Details on the CFTC’s New Self-Reporting Policy
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…
Continue Reading No Action Relief Regarding Variation Margin Rules