Posts Tagged ‘CFTC’
Another Common Sense Win For End-Users Under Dodd-Frank
Better late than never. Last week the CFTC provided a no-action letter recommending that the Commission does not enforce the requirement for inter-affiliate swap reporting under Part 45 governing Swap Data Repository (SDR) rules. Under these rules, a non-financial corporate that centralizes its hedging activity by consolidating its group needs into a larger dealer-facing swap…
Read MoreVerdict on regulation of Fx Swaps & Forwards: still waiting, but reporting to SDRs will be required
Foreign Exchange dealers, hedgers, SEFs and DCOs eagerly awaited clarification on whether or not FX swaps and forwards would be classified as a Swap under the CFTC definitional rule passed on July 10th. Almost two years ago, the U.S. Treasury secretary had received the option under Dodd-Frank to determine if these commonly used derivatives should…
Read MoreTwo years later, the Dodd-Frank train has left the station.
With the passing of the Swap Definition rule on Tuesday, July 10th the clock really starts ticking as some key rules are going into effect this fall. Any rational person would assume that before you write rules governing Swaps, you start with the simple task of defining the Swap. Unfortunately life in the derivative world…
Read MoreBack to the Future: House Votes to Put Margin Exemption Back into Dodd-Frank
This week the U.S. House of Representatives voted 370-24 to amend Dodd-Frank to allow non-financial end users to be exempt from being required to post margin for OTC derivative trades.
Read MoreReady to Report? Swap Dealers May Need to Report to SDRs as Early as July 2012
It is hard to see how Swap Dealers, MSPs, SEFs and DCOs can realistically and properly plan and implement a technology undertaking of this magnitude without having SDRs approved, let alone ready to go themselves.
Read MoreReval Comments to CFTC on Margin Rules
Comments to the CFTC on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants closed on Monday. Reval’s comment letter outlines potential impacts to end-users.
Read MoreCFTC and Dodd-Frank: Swaps Are Still Legal After July 16
Whatever the final date is for implementing Dodd-Frank, Reval CEO Jiro Okochi says market participants will likely need more than a year to properly comply.
Read MoreEnd-User Clearing Exemption Marginalized By Swap Dealer Margin Rules
Reval CEO Jiro Okochi urges End-Users to pick up the pen or make the pilgrimage to DC before the proposed margin requirements issued by the Prudential Regulators and CFTC become final, as they will have a direct cost impact on End-Users, whether it’s through legal fees or the cost to fund the posting of collateral.
Read MoreEnd of Comments to CFTC on End-User Exemption
The door has closed on comments to the CFTC on the end-user exemption, and hopefully the final rule will not have any surprises in it.
Read MoreMore Clarity on the End-User Clearing Exemption: FAS 133 (ASC 815) Ratified, Small Banks in Limbo
The big fear of just relying on FAS 133 was for all of the end-users who would not get the clearing exemption because either they could not be bothered to comply with FAS 133 or because their hedging programs did not work well under FAS 133, like many commodity hedges. The CFTC’s approach does allow the flexibility to leverage FAS 133 documentation where a company can and use other approaches where a company cannot.
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