Category: Policy and Research

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Extension of Relief for Oral Record Keeping Requirements for Registered Commodity Trading Advisors (CTAs) who are Members of a SEF or DCM

On December 16, 2014 the staff of the CFTC issued a no-action letter (CFTC Letter 14-147 or the “December Letter”) extending relief from certain oral record keeping requirements under Rule 1.35(a).  As background, Rule 1.35(a) requires that registered CTAs that are members of swap execution facilities (SEFs) or designated contact markets (DCMs) are required to … Continue Reading

Highlights from CFTC’s Global Markets Advisory Committee Discussion on Bitcoin

On October 9, 2014 the CFTC’s Global Markets Advisory Committee held a meeting focused on the clearing of Non-Deliverable FX Forwards and also with respect to bitcoin.  This post will focus exclusively on the discussion related to bitcoin. A few highlights from the discussion on bitcoin include the following: Thomas Leahy from the CFTC staff … Continue Reading

Issues and Trends of Interest to Buy-Side Derivatives End-Users: ISDA Publishes Survey

ISDA recently published the results of a survey that it conducted to identify key issues and trends for the buy-side, derivatives end-user community.  The results are fascinating and, we blelieve, accurately reflect the experiences of many market participants and professionals that are involved in the over-the-counter (OTC) derivatives markets.  The following is a brief summary of … Continue Reading

Swap Execution Facility to Trade Bitcoin Swaps

TeraExchange, LLC (TeraExchange), a swap execution facility (“SEF”) registered with the Commodity Futures Trading Commission (“CFTC”), has announced it will begin trading a non-deliverable forward based upon the U.S. Dollar price of bitcoin (“Bitcoin Swap”). TeraExchange filed a self-certification application for the Bitcoin Swap with the CFTC on September 11, 2014 and issued a press … Continue Reading

ISDA to the World: At 65% of the Market, the Buy-side Matters

An ISDA Research Study issued on August 11th  provides statistical support of our experience as practitioners – the buy-side matters when it comes to over-the-counter (OTC) derivatives. In this Q&A-styled posting, we we will explore a few highlights of this Research Study, as we believe that it offers valuable insights into the trends in the OTC derivatives … Continue Reading

Federal Reserve Bank of Boston President Calls for Further Reform of the Repo Market

On August 13, 2014, the Federal Reserve Bank of Boston and the Federal Reserve Bank of New York sponsored a “Workshop on the Risks of Wholesale Funding.” Eric S. Rosengren, President & Chief Executive Officer of the Federal Reserve Bank of Boston, gave the keynote address which focused on the source of funding by broker-dealers … Continue Reading
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