BR Derivatives Report

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…

October 25, 2023November 9, 2023

CFTC’s GMAC: Bank Capital Proposals Will Harm Cleared Derivatives Markets and Improvements Needed to Variation Margin Processes in Non-Cleared Markets

Andrew P. Cross — The Global Markets Advisory Committee (“GMAC”) of the U.S. Commodity Futures Trading Commission (“CFTC”) issued on June 4, 2024, a report on cleared derivatives and recommendations for non-cleared derivatives that will be of interest to all derivatives markets participants (i.e., dealers and buy-side firms). The report focused on the potential adverse impact…

June 6, 2024June 6, 2024

Part 12: Amendments to Other CFTC Regulations to Account for Proposed Regulation §1.44

Andrew P. Cross — This post is the final installment of our multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”). This post provides an overview of proposed changes to other CFTC regulations that will be made if the Proposed Rule…

March 21, 2024March 21, 2024

Part 11: Information and Disclosure Requirements in the Separate Account Context

Andrew P. Cross — This post is the next installment of multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”). This post will summarize information and disclosure requirements under proposed CFTC Regulation §1.44(h) that, if adopted, will apply in the separate…

March 20, 2024March 20, 2024

Part 10: Capital, Risk Management, and Segregation Calculations by FCMs

Andrew P. Cross — This post is the next installment of a multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”). Sub-paragraph (g) of CFTC Regulation §1.44 permits a futures commission merchant (“FCM”) to treat each separate account as a distinct…

March 19, 2024March 19, 2024

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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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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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