Jon Ammons

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Jon Ammons is an associate in the Washington, DC office of Norton Rose Fulbright. His practice focuses on regulatory and transactional issues related to commodities and derivatives products. Specifically, Jon advises derivatives market participants, including swap dealers, SEFs, FCMs, CPOs, CTAs, pension plans and end-users regarding compliance with Dodd-Frank regulations from the CFTC and SEC. Jon also assists buy and sell-side market participants in negotiating derivatives agreements related to financial and non-financial commodities, including swaps documented under ISDA Master Agreements.

Latest Articles

A former futures trader recently agreed to a settlement order from the U.S. Commodity Futures Trading Commission (“CFTC”) imposing a permanent trading ban for spoofing and manipulation, and pled guilty to criminal charges of manipulation and wire fraud, for trading done in the precious metals market. David Liew was a trader on a major financial institution’s precious metals desk from December 2009 to February 2012 and, according to certain news reports, was based in…
Today, in a move on its long-pending proposals, the CFTC: (1) re-proposed its new speculative position limits rules (the “Re-Proposal”), which would impose federal limits on 25 physical commodity futures contracts and their “economically equivalent” futures, options, and swaps; and (2) separately issued final rules relating to position aggregation requirements (the “Final Aggregation Rules”). We will cover the details of the Re-Proposal and the Final Aggregation Rules in the days ahead.…
On October 13, 2016, the Commodity Futures Trading Commission (“CFTC’”) unanimously issued an order establishing December 31, 2018 as the swap dealer de minimis threshold phase-in termination date (the “Order”). The Order is effective October 13, 2016. Summary of the Order Pursuant to CFTC Regulation 1.3(ggg), a person shall not be deemed to be a swap dealer (“SD”) unless its swap dealing activity exceeds an aggregate gross notional amount of $3 billion (measured over a rolling…
On October 11, the Commodity Futures Trading Commission (“CFTC’”) issued proposed rules and interpretations (the “Proposed Rule”) addressing the cross-border application of certain swap provisions of the Commodity Exchange Act. Generally speaking, the Proposed Rule aims to: (1) codify certain aspects of the CFTC’s earlier guidance on the cross-border aspects of its swaps regulations (the “Cross-Border Guidance”), (2) amend the list of swaps that would cause a non-U.S. person to be…
The United States Securities and Exchange Commission (SEC) recently finalized a regulation pursuant to Title VII of the Dodd-Frank Act regarding the requirement for security-based swap data repositories (SBSDRs) to make security-based swap data available to other domestic and foreign regulators. Pursuant to the final regulation, SBSDRs must make available security-based swap data, including individual counterparty trade and position data, to several US financial regulators and the Federal Reserve banks, the US Department of Justice,…
On September 8, 2016, the CFTC held an open meeting where the Commissioners: (i) unanimously approved two final rules regarding system safeguards and testing requirements for derivatives trading platforms, clearinghouses, and data repositories, and (ii) approved, over Commissioner Bowen’s dissent, a “comparability determination” for purposes of substituted compliance with Japan’s regulations regarding margin requirements for uncleared swaps. Also noteworthy, though, were the closing remarks made by Chairman Timothy Massad, where he listed his priorities for…
On May 10, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) issued a notice of proposed amendment to its 2013 order exempting specified electric energy transactions in certain Regional Transmission Organizations (“RTOs”), Independent System Operators (“ISOs”) and the Electric Reliability Council of Texas (“ERCOT”) from regulation under certain provisions of the Commodity Exchange Act (“CEA”) and the CFTC’s regulations thereunder (the “RTO-ISO Order”). Scope of the RTO-ISO Order The RTO-ISO Order exempts from…
ICE Futures US (“ICE”) adopted a new rule, effective March 18, 2016, that provides relief from position limit aggregation requirements applicable to “owned entities.” Specifically, the rule amendment permits certain affiliated entities to disaggregate their positions for purposes of compliance with ICE’s position limits. Background ICE imposes spot-month position limits on all its futures contracts, which limit the number of futures positions (other than those held for bona fide hedging) that a person may hold…
Market participants must be mindful of the robust enforcement environment at the CFTC and U.S. futures exchanges.  In 2015, the CFTC brought numerous enforcement actions and continued to impose aggressive civil monetary penalties on market participants, including energy and agricultural companies.  Significantly, the CFTC also started to pivot from implementing to enforcing its regulations promulgated under the Dodd-Frank Act.  In light of its scarce resources, the CFTC also has put pressure on futures exchanges such…
The CFTC has proposed a set of rules, referred to collectively as proposed Regulation AT, that would, for the first time, impose risk control and other requirements governing algorithmic trading systems (ATSs) in futures contracts, options, and swaps traded on designated contract markets (DCMs) such as CME, CBOT, NYMEX, and ICE Futures US.  Regulation AT would impose requirements on:  i) market participants using ATSs (called AT Persons); ii) clearing member futures commission merchants (FCMs)…