Insights

OCC Expands Recovery Planning Requirements

Summary: Situation Overview: The Office of the Comptroller of the Currency (OCC) finalized revisions to Recovery Planning Guidelines, which substantively change the scope and expectations for recovery plans. What: The OCC is increasingly focusing…

CFTC Enforcement Takes Aim at Position Limit Violations

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Key Takeaways: In the last 3 months, the Commodity Futures Exchange Commission (CFTC) has issued 3 orders against firms violating positions limits, totaling $2.3 million in fines. CFTC position limit rules apply not only to swap dealers,…
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By: Robert Lulgjuraj, Tim Brown