Recent Articles

Swap Dealer Definition Final Rule Delayed

Andrew Cross
February 22, 2012 00:10

21 February: CFTC pulled the swap dealer / MSP definitional rule from its agenda for the 23rd February meeting. Revised itinerary is available here. Good day. Good luck keeping up with everything. TSR

On Deck for February 23rd CFTC Meeting: Swap Dealer Final Rule; Conflicts of Interest and Recordkeeping Final Rule for Swap Dealer; Proposed Rule for Large Notional Off-Facility Block Trades

Andrew Cross
February 16, 2012 22:12

Long Title, Short Posting CFTC meeting will be held on February 23rd at 9:30 a.m. EST. You can get more information including dial-in, webcast, etc. from the CFTC by clicking here. Good day. Good news about that swap dealer definitional rule (at least the uncertainty will be over). TSR

CFTC Rule 4.5: Is it an Alternative or an Additional Net Notional Test?

Andrew Cross
February 13, 2012 11:57

TSR is still preparing its overview of new Rule 4.5, but we want to share a thought with you while we do that. The recent amendment to CFTC Rule 4.5 includes what the adopting release refers to as an "alternative net notional test" and if you read the adopting release you would walk...

Attention Hedge Funds, Mutual Funds, ETFs, CPOs and CTAs: CFTC Amends Part 4 of Its Rules

Andrew Cross
February 11, 2012 14:26

NEW RULES WILL AFFECT ALL MONEY MANAGEMENT INDUSTRY PARTICIPANTS On February 9th, the CFTC issued final amendments to Part 4 of its rules that will impose additional compliance obligations on nearly every category of money management industry participant, including: Investment advisers...

Rule 4.5 and 4.13: Behold the Amendments

Andrew Cross
February 09, 2012 17:32

Ok. Click here  for the rule - hot off the e-presses... Good day. Good digesting. TSR

Uncertainty: Before and After Regulatory Reform

Andrew Cross
January 17, 2012 16:34

Here at TSR, we do not usually do "free-form thinking" posts - rather, we try to focus on concrete regulatory and transactional issues related to derivatives. But, today is an exception.... In plowing through the Volcker Rule(s), the plethora of Title VII's reforms, what seems like a...

Financial Data for Futures Commission Merchants: A Due Diligence Tool

Andrew Cross
January 13, 2012 15:24

On a monthly basis, the CFTC publishes financial data for every registered FCM based upon the reports filed by that FCM. The reports, while brief, contain useful information, such as: 1) The capital requirement for the FCM and available adjusted net capital; 2) The excess capital held by the...

January 11th CFTC to Consider 3 Final Rules PLUS Volcker Rule Proposal

Andrew Cross
January 04, 2012 22:19

When: January 11th @ 9:30 a.m. EST (4:30 p.m. SAST if you are in Cape Town, South Africa, where I might add it appears to be 68 degrees Fahrenheit at the present moment...not too bad for January 12th...but then again, it is SUMMER there and 20 degrees Fahrenheit where I frigidly sit...

MF Global: Treatment of Repurchase Agreements in the SIPC Order GUEST COLUMN BY TODD ZEREGA

Andrew Cross
November 23, 2011 18:37

GUEST COLUMN BY TODD ZEREGA, PARTNER AT REED SMITH LLP As reported on other TSR postings, on October 31, 2011 SIPC filed a compliant seeking the appointment of a Trustee to commence the liquidation of MF Global Inc. under the Securities Investor Protection Act. On the same day Judge...

MF Global Claim Forms Available

Andrew Cross
November 23, 2011 18:35

Go to www.mfglobaltrustee.com and you can get your securities and commodity customer account claim forms. Due January 31, 2012 for customer claims. Good day. Good filing. TSR