Category: Security-Based Swaps

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Swaps and Retail Commodity Transactions (Leverage, Margin or Financing: Will We Know It When We See It or Only After It Has Been Identified As Such?)

This post builds upon an idea presented in Part 4 of current series of posts on considerations for investment funds and advisers related to cryptocurrency derivatives. In particular, this post provides additional perspectives on the relationship of leverage, margin, and financing to two commodity interests: “retail commodity transactions” and a “swaps”.  We decided to present … Continue Reading

Cryptocurrency Derivatives, Funds and Advisers: Key Considerations Under U.S. Commodity Laws (Part 4: About the Interests of Interest)

This post is the fourth in a series that outlines key considerations for investment funds and their advisers regarding the application of the U.S. commodity laws to cryptocurrency derivatives.  This post is intended to be a primer on the topic and is not legal advice.  You should consult with your counsel regarding the application of … Continue Reading

A Compendium of 2015 Regulatory Activity by the SEC In Respect of Security-Based Swaps

Links to Text of Rules Final Rules: http://www.sec.gov/rules/final.shtml Proposed Rules: http://www.sec.gov/rules/proposed.shtml 2015 Timeline Final Rules (F) and Proposed Rules (P) (F) February 2015 Finalized Registration and Governance Rules that Apply to SBS Data Repositories (F) February 2015 Finalized SBS Data Reporting Rules (P) February 2015 Proposed Rules to Implement the Finalized Reporting Rules, Establish Certain … Continue Reading
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