United States


DateTitle / DescriptionDocuments
December 27, 2012
By When? – The CFTC’s Dodd-Frank Compliance Dates
Mayer-Brown has prepared this matrix to catalog the “by when” dates presently found in many of the final and proposed regulations published by the Commodity Futures Trading Commission, as modified by recent moderating actions of the CFTC and its staff.
DF Effectiveness Timelines.pdf
December 19, 2012
Implementing Dodd-Frank: The CFTC’s Moderating Actions - ISDA’s Requests (updated December 19, 2012)
Presentation by Joshua Cohn and Curtis Doty, Mayer Brown LLP. This is an update of the presentation originally dated December 16, 2012.
CFTC No Action - Mayer Brown ISDA slides 121912.pdf
November 26, 2012
Re-Opening of Comment Period re: Margin and Capital Requirements for Covered Swap Entities – Comments on Margin Requirements
Letter to OCC, Federal Reserve, Federal Housing Finance Agency, Farm Credit Administration and Federal Deposit Insurance Corporation
Margin for Uncleared Letter.pdf
November 26, 2012
Comment Letter on Margin for Uncleared
Comment Letter to the US Prudential Regulators regarding Margin for Uncleared
Margin for Uncleared Letter.pdf
November 17, 2012
Request for Division of Market Oversight Staff No-Action Letter Pursuant to CFTC Regulation 140.99, Reporting Requirements for Bespoke or Complex Products
ISDA letter to Mr. Richard Shilts, Director, Division of Market Oversight, Commodity Futures Trading Commission (CFTC)
NAL - Reporting of Bespoke or Complex Swaps.pdf
October 25, 2012
Comment Letter to CFTC on Reporting of Post-Priced Swaps
Letter to Richard Shilts, Director, Division of Market Oversight, Commodity Futures Trading Commission
CFTC Letter PRS final - 102512.pdf
October 25, 2012
Comment Letter on the Reporting of “Post-Priced” Swaps
Letter to the Commodity Futures Trading Commission (CFTC) regarding the Reporting of “Post-Priced” Swaps
CFTC Letter PRS final - 102512 (3).pdf
October 19, 2012
Notice of Proposed Rulemaking - Regulatory Capital Rules: Standardized Approach for Risk-weighted Assets; Market Discipline and Disclosure Requirements
Letter to Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation. This response is targeted to the specific risk-based capital requirements for derivative and repo-style transactions that are cleared on central counterparties (CCP Rules). (OCC RIN 1557-AD46; OCC Docket ID OCC-2012-0009; FRB RIN 7100 AD 87; FRB Docket No. R-1442; FDIC RIN 3064-AD96)
Letter to Joint Agencies 19 October 2012 re CCP exposures.pdf
October 12, 2012
Comment Letter on Further Definition of "Swap", "Security-Based Swap", and "Security-Based Swap Agreement"; Mixed Swaps; Security-Based Swap Agreement Recordkeeping
Letter to the Commodity Futures Trading Commission (CFTC) regarding Further Definition of "Swap", "Security-Based Swap", and "Security-Based Swap Agreement"; Mixed Swaps; Security-Based Swap Agreement Recordkeeping
CFTC letter - defintions - vol optionality and usage 101212.pdf
October 1, 2012
Dodd-Frank Act v. EMIR - Confirmation, reconciliation, compression and documentation rules: October 2012
This paper summarises and compares: CFTC rules: the final rules adopted by the U.S. Commodity Futures Trading Commission (CFTC) in August 2012 under section 4s(i) of the Commodity Exchange Act (CEA) (added by section 731 of the Dodd-Frank Act) prescribing standards for swap dealers (SDs) and major swap participants (MSPs) related to the timely and accurate confirmation, reconciliation, compression and documentation of swaps (17 CFR §23.500 through §23.505); and Draft EU rules: the corresponding provisions of the draft regulatory technical standards (RTS) specifying the requirements of Article 11(1) of the EU Regulation on OTC derivatives, central counterparties and trade repositories (EMIR) requiring financial counterparties (FCs) and non-financial counterparties (NFCs) to have appropriate procedures and arrangements to measure, monitor and mitigate operation risk and counterparty credit risk. The draft RTS were adopted by the European Securities and Markets Authority (ESMA) and submitted to the European Commission for endorsement in September 2012 This paper is not intended to be comprehensive or to provide legal advice.
Dodd-Frank Act v. EMIR.pdf