Recent Regulatory Activity

CFTC, SEC, U.S. Prudential Regulators:

  • On January 6, the CFTC issued a No-Action Letter providing relief to swap dealers from compliance with certain CCO reporting line requirements (see Press Release).
  • Also on January 6, the CFTC published an extension for a Proposed Information Collection Notice for DCO reporting requirements (comments due February 5, 2015).
  • On January 5, the CFTC published a clarification regarding the reopening of its comment periodfor its Proposed Rules on Position Limits for Derivatives and Aggregation of Positions (comments due by January 22, 2015; see Press Release and statement from CFTC Commissioner Bowen).  The clarification notes that, in addition to comments on the proposal itself, commenters may also addressed issues discussed at the Dec. 9 Agricultural Advisory Meeting or related materials posted on the CFTC website (see Press Release).
  • On December 29, the CFTC issued an extension of relief for FCMs from certain acknowledgment letter requirements (see Press Release).
  • Also on December 29, the SEC published a list of rules that will be reviewed pursuant to the Regulatory Flexibility Act (comments due January 28, 2015).
  • On December 23, the OFR published a blog post regarding U.S. progress with G20 priorities.
  • On December 22, the CFTC took two actions:
  1. The Commission issued an advisory an no-action letter regarding annual SD, MSP and FCM CCO reports (see Press Release); and
  2. The CFTC’s subcommittee on FX Markets submitted a report to the GMAC regarding recommendations on an FX NDF clearing mandate (see Press Release)
  • Also on December 22, the CFTC and SEC published their semiannual regulatory agendas.  Comments on the SEC agenda are due by January 21, 2015.
  • On December 19, the CFTC issued a No-Action Letter providing relief from certain CPO registration requirements for ILS issuers (see Press Release).
  • Also on December 19, the OCC released a report on bank trading and derivatives activity in the 3rd quarter of 2014 (see Press Release).
  • On December 18, the GAO issued a report analyzing regulators’ Dodd-Frank analytical and coordination efforts (see highlights).
  • On December 16, the CFTC issued a No-Action Letter providing relief to CTAs from certain recordkeeping requirements under 1.35(a) (see Press Release).
  • Also on December 16, the Federal Reserve and OCC released an Interim Final Rule on Regulatory Capital Rules, Liquidity Coverage Ratio: Interim Final Revisions to the Definition of Qualifying Master Netting Agreement and Related Definitions.  The Interim Final Rule is effective January 1, 2015; comments are due by March 3, 2015.


  • On December 24, the IMF released a working paper analyzing CDS settlement auctions.
  • On December 22, ESMA released an annex to the MiFID II draft consultation on cost-benefit analysis.
  • On December 19, ESMA released a final report on technical advice to the EC regarding MiFID II and MiFIR, along with a draft consultation (also see Annex).  Comments on the Consultation are due by March 2, 2015.
  • Also on December 19, ESMA released a final report on drafting implementing technical standard on main indices and recognized exchanges under CRR.