Swaps

They are vital steps for putting in place a registration framework for SBS dealers and major participants. I note, however, that the registration rules will ...

The adopting rules require a senior officer of the applicant to certify that, after due inquiry, he or she has reasonably determined that the applicant ...

My concerns with this release include the repeated use of certifications as part of the registration process. I disagree with these provisions in part because ...

These new registration rules are fairly straightforward. They establish registration forms and certifications that the Commission needs to register entities that will be trading a ...

The CFTC must make a more concerted effort to fix its swaps trading rules in accordance with the letter and spirit of Title VII of ...

The analysis of the MAT rulemaking should not be focused on who makes the MAT determination, swap execution facilities (SEFs) or the CFTC. That would ...

Last week, the CFTC unanimously approved a new proposed rule designed to prevent U.S. swaps dealers from escaping its margin requirements by conducting business overseas. ...

This CFTC proposed rule from 2015 would apply margin requirements to cross-border transactions, as a well to close a loop-hole regarding international swaps.

I would also like to say a word about our Cross-Border Guidance, which discussed how the Commission would generally apply Dodd-Frank requirements to cross-border swap ...

I am comfortable supporting today’s release, but for the reasons discussed below, continue to harbor some doubts as to whether we have selected the approach ...