Insights

CFTC Swap Rules for Renewable Energy Transactions: What VPPA Participants Must Know

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Summary Situation Overview: Virtual power purchase agreements (VPPAs) are classified as swaps under the Commodity Exchange Act (CEA). All firms engaging in VPPAs are obligated to comply with certain CFTC regulations, including non-financial…

CFTC Issues No-Action Relief for Swap Data Reporting Error Corrections

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Summary Situation Overview: On December 10, 2025, the Commodity Futures Trading Commission (CFTC) issued no-action relief regarding the correction of errors in swap transaction and pricing data submitted to a swap data repository (SDR). What:…

Patomak Global Partners Named One of the Top Consulting Firms in Fintech by Chambers & Partners

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WASHINGTON D.C. – Patomak Global Partners is honored to share that it has been ranked as one of the top fintech consultancies in the United States for the second consecutive year by Chambers and Partners in the Chambers FinTech Guide 2026.  Each…

SEC’s 2026 SBSD and SBSEF Examination Priorities: What Firms Should Expect and How to Prepare

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Summary Situation Overview: The Securities and Exchange Commission’s (SEC) Division of Examinations (Division) released its 2026 examination priorities for Security-Based Swap Dealers (SBSDs) and, for the first time, examinations for Security-Based…

SBSD De Minimis Threshold Phase-In: Potential Relief Ahead, but Firms Should Prepare for All Scenarios

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Summary Situation Overview: The SEC’s temporary de minimis thresholds for security-based swap dealing activity ($8 billion for credit default swaps and $400 million for non-CDS) are scheduled to change following the expiration of the current…

Spoofing Enforcement Cases and Steps to Protect Your Firm

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Summary Situation Overview: Domestic and foreign regulators continue to pursue actions against firms for spoofing and market manipulation activities. What: There is a continuing need for vigilance in detecting and preventing spoofing, particularly…

Pamela Geraghty Joins the CFTC Observer Podcast

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Patomak’s Pamela Geraghty joined The CFTC Observer Podcast to share an insider’s perspective on the derivatives industry and her time at the Commodity Futures Trading Commission. She discussed the agency’s evolving regulatory priorities,…

Patomak Team Supports PrizePicks as First Sports Entertainment-Focused Futures Commission Merchant with the CFTC and NFA

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Patomak Global Partners was honored to be a part of the team supporting PrizePicks as it registered as the first Sports Entertainment-focused Futures Commission Merchant (FCM) with the Commodity Futures Trading Commission (CFTC) and National…

CFTC Eases SDR Error Notification Requirements With New No-Action Relief

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Summary: Situation Overview: On July 31, 2025, the Commodity Futures Trading Commission (CFTC) provided reporting counterparties relief from the swap data repository (SDR) reporting requirement to submit an error correction notification (ECN)…

The Future of U.S. Crypto Regulation: Analyzing the CLARITY Act and the RFIA

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Summary: Context: The U.S. Congress is actively developing a robust regulatory framework to govern digital assets, aiming to provide clarity and stability to the rapidly evolving industry. What: The House of Representatives passed the CLARITY…

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity

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Summary: Situation Overview: The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. What: On April 25, the Federal…

CFTC Reminds Non-U.S. Swap Dealers of Annual Report Requirements in Newly Issued Advisory

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On December 2, the CFTC reminded non-U.S. swap dealer chief compliance officers of annual reporting requirements. This Staff Advisory asserts that many non-U.S. swap dealers have been deviating from chief compliance officer annual reporting…