Welcome to The BR Derivatives Report!

Whether you work for a financial institution, investment adviser, commodity trading firm, family office, public company, registered investment company, or private fund, or are just curious about the derivatives market, you are in the right place. Authored by Blank Rome LLP’s seasoned Finance and Investment Management attorneys, The BR Derivatives Report is here to shed…

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Crypto and Carbon and Governance…Oh My! (Was There Ever Really a Kansas for Digital Assets and Environmental Commodities?)

Andrew P. Cross — Reflections on CFTC Commissioner Johnson’s Speech at the Atlanta Economics Club On November 13, 2023, Commodity Futures Trading Commission (“CFTC”) Commissioner Kristin Johnson delivered a keynote address to the Atlanta Economics Club titled “Policing the (Token) Economy: Introducing Corporate Governance and Market Structure Reforms in Crypto and Environmental Commodities Markets.” The speech…

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2023 Enforcement Results Released by CFTC

Andrew P. Cross — On November 7, 2023, the U.S. Commodity Futures Trading Commission (“CFTC”) released its enforcement results for Fiscal Year 2023 (“FY 2023”). The following are select highlights: 96… …enforcement actions were filed by the CFTC’s Division of Enforcement of which 62 were administrative cases and 34 were injunctive cases. 12… …of the 96…

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Transactional Corner: NOW Is the Time to Complete Your MSFTA Negotiations…Seriously

Andrew P. Cross — Mandatory TBA Margining under FINRA Rule 4210 Starts May 22, 2024 On August 18, 2023, the Financial Industry Regulatory Authority (“FINRA”) issued Regulatory Notice 23-14 announcing that mandatory margining of certain delayed delivery agency mortgage-backed securities, including so-called TBAs (or “To Be Announced” securities), will go into effect on May 22, 2024. This regulatory…

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Disclosure Obligations for CPOs and CTAs under Proposed Amendments to CFTC Regulation 4.7

Andrew P. Cross — This article is the second in a series on a recent rule proposal by the U.S. Commodity Futures Trading Commission (“CFTC”) to amend CFTC Regulation 4.7. Introduction As detailed in an October 9 article at The BR Derivatives Report, the CFTC recently proposed amendments to CFTC Regulation 4.7. If adopted, these amendments will substantially…

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The BR Derivatives Report explores the complex world of derivatives to update readers regarding compliance and transactional developments occurring in this financial marketplace.

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Blank Rome’s finance attorneys have significant depth of talent in financial services legal matters and extensive experience in structuring, negotiating, and documenting all types of derivatives and complex financing transactions. Our team regularly represents many of the nation’s leading players in lending, leasing, and specialty finance in a broad range of services.

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Blank Rome’s investment management attorneys represent investment advisers and their clients, including registered investment companies and their boards. In the derivatives space, we have concentrated, market-leading experience related to the use of derivatives by registered investment advisers, registered investment companies, private funds, and a wide range of institutional investors.

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Please contact Blank Rome for permission to reprint. Notice: The purpose of this update is to identify select developments that may be of interest to readers. The information contained herein is abridged and summarized from various sources, the accuracy and completeness of which cannot be assured. This update should not be construed as legal advice or opinion, and is not substitute for the advice of counsel.

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