Corporate & Financial Weekly Digest

Corporate & Financial Weekly Digest

Tag Archives: no-action letter

CFTC Extends Relief From Transaction-Level Requirements for Non-US Swap Dealers

Posted in CFTC, Derivatives
The Division of Swap Dealer and Intermediary Oversight, the Division of Clearing and Risk and the Division of Market Oversight (collectively, the Divisions) of the Commodity Futures Trading Commission have extended relief previously provided in a series of previous no-action letters relating to transaction-level requirements for non-US swap dealers (non-US SDs). Specifically, the Divisions have… Continue Reading

CFTC Extends Previously Granted No-Action Relief for Swap Dealers Complying With EU Requirements

Posted in CFTC, Derivatives
On April 18, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued No-Action Letter 17-22, which extends relief previously granted under CFTC No-Action Letter 17-05. CFTC No-Action Letter 17-05 allowed certain swap dealers to substitute compliance with the non-centrally cleared OTC derivative margin requirements applicable in the European Union (the… Continue Reading

SEC Simplifies Process for Electronically Filing Broker-Dealer Annual Reports

Posted in Broker-Dealer, Derivatives
The Division of Trading and Markets (Division) of the Securities and Exchange Commission has updated its no-action relief to broker-dealers and over-the-counter (OTC) derivatives dealers from the requirement to file annual and supplemental reports with the SEC in paper form. The Division had previously issued a no-action letter in December 2015 that provided relief to… Continue Reading

CFTC Issues No-Action Letter Regarding Use of Security-Based Swaps in Initial Margin Calculations for Uncleared Swaps

Posted in CFTC, Derivatives
On August 23, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight and Division of Clearing and Risk (the Divisions) issued a response to the International Swaps and Derivatives Association (ISDA), which had requested the CFTC to clarify whether a covered swap entity (CSE) is permitted to include security-based swaps within the… Continue Reading

CFTC Extends No-Action Relief for DCMs and SEFs Pertaining to Clerical and Operation Errors in Swaps Trades

Posted in CFTC, Derivatives
On June 10, the Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk issued No-Action Letter No. 16-58 granting designated contract markets (DCMs) and swap execution facilities (SEFs) relief from relevant provisions of CFTC regulations that would otherwise prohibit the DCM or SEF from facilitating transactions entered into to correct… Continue Reading

CFTC Approves Rules Amending Cleared Swaps Data Reporting and Recordkeeping Requirements

Posted in CFTC, Derivatives
On June 14, 2016, the Commodity Futures Trading Commission announced the approval of amendments to Part 45 of the CFTC’s regulations, which pertain to the reporting and recordkeeping obligations involved in cleared swaps transactions. The amendments seek to clarify certain aspects of the existing Part 45 rules, including the roles of registered entities and swap… Continue Reading

SEC Issues No-Action Relief Pursuant to Rule 14a-8(i)(9)

Posted in SEC/Corporate
As previously reported in the Corporate and Financial Weekly Digest edition of October 30, 2015, the Securities and Exchange Commission’s Division of Corporation Finance (“Division”) issued Staff Legal Bulletin No. 14H (SLB 14H) on October 22, 2015. SLB 14H established a new standard for determining when a shareholder proposal conflicts with a company proposal (providing… Continue Reading

CFPB Issues Final Policy on No-Action Letters

Posted in Banking, Derivatives, Dodd-Frank Developments
The Consumer Financial Protection Bureau (Bureau) issued its final policy on its issuance of no-action letters on February 18, which is intended to further objectives under section 1021 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). Under the Policy, Bureau staff would, “in its discretion, issue no-action letters (NALs)… Continue Reading