Tag Archives: Rule 1.35

Upcoming CFTC Roundtables: CPO Risk Management and End Users

By Andrew Cross and Tom Watterson We want to let everyone know about two upcoming CFTC Roundtables, the dates and topics are below. March 18th– Risk management procedures for CPOs, including managing investment risk, operational risk, and compliance or regulatory risk. April 3rd– Dodd-Frank issues for end-users of swaps, including recordkeeping under CFTC Rule 1.35, forward … Continue Reading

CFTC Provides Time Limited Relief to Oral Recordkeeping Requirements for CTAs — UPDATE to: One Consequence of Becoming a SEF Member – Increased Recordkeeping Requirements

By Andrew Cross and Tom Watterson In our November 1, post “One Consequence of Becoming a SEF Member – Increased Recordkeeping Requirements” we sought to raise awareness regarding increased recordkeeping requirements for SEF members under CFTC Rule 1.35(a). CFTC Rule 1.35(a) generally requires “members” of a SEF (or an exchange) to maintain oral records (i.e., … Continue Reading

One Consequence of Becoming a SEF Member – Increased Recordkeeping Requirements

We wanted to raise awareness on a point that has not received much attention to date: increased recordkeeping requirements for SEF members. At the outset, many SEFs use the term “participant” synonymously with “member.” So, if you are one of the many swap market participants who have received a “Participant Agreement” in the┬ápast┬ámonth, then this … Continue Reading
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