Adam P. Haft

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On September 11, the Commodity Futures Trading Commission (CFTC) announced that the Division of Swap Dealer and Intermediary Oversight (DSIO) and the Division of Market Oversight (DMO) had issued CFTC Letter No. 20-26, further extending certain elements of the temporary no-action relief issued in response to the COVID-19 pandemic that are set to expire on September 30. The extended relief expires on January 15, 2021.…
Continue Reading CFTC Further Extends Certain No-Action Relief to Market Participants in Response to COVID-19

On September 15, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO) granted no-action relief to Tassat Derivatives LLC, a CFTC-registered swap execution facility (SEF), from SEF reinstatement requirements under CFTC Regulation 37.3(d). The no-action relief set out in CFTC Letter No. 20-27 is subject to certain conditions.…
Continue Reading CFTC Staff Provides No-Action Relief to Registrant from SEF Reinstatement Requirements

On August 14, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 20-28 that included an updated Security Futures Risk Disclosure Statement (the “2020 Statement”). The uniform Security Futures Risk Disclosure Statement (the “Statement”) was jointly developed by FINRA, the National Futures Association (NFA) and several other self-regulatory organizations. The Statement is composed of nine sections and discusses the characteristics and risks of standardized security futures contracts traded on regulated US exchanges.…
Continue Reading FINRA Releases an Updated Security Futures Risk Disclosure Statement

On August 17, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 20-29 to request comment on the practice of internalizing customer trades in the corporate bond market after obtaining auction responses, commonly known as “pennying.” The Securities and Exchange Commission’s Fixed Income Market Structure Advisory Committee (FIMSAC) defined “pennying” as a practice where a dealer initiates a bid or offer-wanted auction process on behalf of a customer, reviews the auction responses, and then executes the customer order itself at a price that either matches or slightly improves the best-priced auction response. FIMSAC stated that pennying may appear to benefit a customer but may harm overall auction competitiveness over time.…
Continue Reading FINRA Requests Comment on the Practice of Pennying in the Corporate Bond Market

On June 22, National Futures Association (NFA) issued Notice I-20-26 announcing that the recent amendments made to Part 3 of its Compliance Rules will become effective on August 31, 2020. NFA Compliance Rule 3-14 was amended to allow an NFA disciplinary panel to impose a monetary penalty of up to $500,000 per rule violation at…

On June 1, Cboe Exchange, Inc. (Cboe) filed with the Securities and Exchange Commission a proposed rule change to amend Rule 8.16 and Rule 9.2 to temporarily extend the filing deadline for certain supervision-related reports, which Cboe previously extended from April 1 to June 1 and from June 1 to June 30. …
Continue Reading CBOE Exchange Proposes to Temporarily Extend the Filing Deadline for Certain Supervision-Related Reports

On May 28, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 20-16 to share common themes observed through discussions with small, mid-size and large firms about the steps they reported taking to transition their associated persons and supervisory procedures to a remote work environment during the coronavirus (COVID-19) pandemic.…
Continue Reading FINRA Shares Practices to Transition to a Remote Work Environment during COVID-19