by Jill Sommers, Jamila Piracci, Sudhir Jain and Nick Grose | Nov 15, 2022 | Patomak Post
CFTC and NFA have issued more than 15 enforcement orders against swap dealers in 2022. Five key pitfalls stand out as a common denominator: failure to report to Swap Data Repositories, failure to provide sufficient disclosures to counterparties, failure to diligently...
by Paul Atkins, Jill Sommers and Fred Hatfield | Sep 27, 2021 | In the News, Newsroom, Opinion
Consider it a warning sign when legislation coming off Capitol Hill includes language – even before it is enacted – indicating a federal agency will need to simplify its related rules. As former Securities and Exchange Commission (SEC) and Commodity Futures Trading...
by Jill Sommers and Jamila Piracci | Dec 3, 2020 | U.S. Regulatory Update
The Commodity Futures Trading Commission (CFTC), the Securities and Exchange Commission (SEC), and the Department of Justice (DOJ) have all issued 2020 guidance informing market participants about evaluations and determinations by enforcement staff and prosecutors in...
by Jill Sommers and Paul Atkins | Sep 22, 2020 | U.S. Regulatory Update
As former regulators, we saw firsthand the important role central counterparties (CCPs) play during periods of heightened stress, including bankruptcies and global financial market downturns. U.S. CCPs have performed as intended and without fail since their inception....
by Jill Sommers and Jamila Piracci | Jun 1, 2020 | Patomak Post
The Commodity Futures Trading Commission (CFTC) voted 5-0 during its open meeting on May 28 to adopt an interim final rule to extend the September 2020 compliance date (Phase 5) for regulatory Initial Margin (IM) , to September 1, 2021. This action is in line with the...