US - CFTC Publishes Concept Release Regarding Review of Exemptions for Swap Dealers

Fri, Mar 27, 2009

The Commodity Futures Trading Commission (CFTC) published a concept release aimed at bringing greater transparency and accountability to the derivatives marketplace.

CFTC is an independent agency with the mandate to regulate commodity futures and option markets in the United States.

The concept release arose from Recommendation Five of the September 2008 "Staff Report on Commodity Swap Dealers and Index Traders with Commission Recommendations" (September 2008 Report).

The recommendation directed Commission staff to review whether to eliminate bona fide hedge exemptions for swap dealers and create new limited risk management exemptions.

The new exemptions would be conditioned upon, among other things:

  1. An obligation to report to the CFTC and applicable self-regulatory organizations when certain noncommercial swap clients reach a certain position level and/or
  2. A certification that none of a swap dealer's noncommercial swap clients exceed specified position limits in related exchange-regulated commodities

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