Sarah R. Adams

Connect: Read more about Sarah R. Adams
Firm/Organization: Katten Muchin Rosenman
Blogs: Corporate & Financial Weekly Digest

Latest Articles

On November 21, the Financial Industry Regulatory Authority issued Regulatory Notice 17-40, which provides member firms guidance as it relates to compliance with Rule 3310 in light of the Financial Crimes Enforcement Network’s (FinCEN) adoption of Customer Due Diligence Requirements (CDD Rule).…
On October 31, the Commodity Futures Trading Commission’s Division of Market Oversight extended no-action relief for certain swaps executed as part of packaged transactions. Transactions where at least one swap is subject to a trade execution requirement and either (1) at least one individual component is a bond issued and sold in the primary market or (2) all other components are futures contracts, are provided relief from the following requirements: Commodity Exchange Act (CEA) Section…
On October 31, the Commodity Futures Trading Commission’s Division of Market Oversight extended no-action relief to swap execution facilities (SEFs) from the requirement to capture post-execution allocation information in their audit trail data. To rely on the no-action relief, SEFs must (1) have a rule requiring market participations to provide post-execution allocation information upon request if the SEF, at the request of the CFTC or otherwise, requests such information, and (2) in the course of…
On October 31, the Commodity Futures Trading Commission issued an order to the Chicago Mercantile Exchange (CME) and its clearing members that are registered futures commission merchants with regard to foreign futures contracts currently listed or that will be listed in the future for trading on the Dubai Mercantile Exchange (DME) and cleared by the CME. The order allows the commingling of funds related to such foreign futures contracts with customer funds related to futures…
The Securities and Exchange Commission has approved the Financial Industry Regulatory Authority rules that (1) consolidate the National Association of Securities Dealers (NASD) and Incorporated New York Stock Exchange registration rules, as well as existing FINRA rules; (2) restructure the representative-level qualification examination requirements; and (3) amend continuing education requirements. The rules will become effective October 1, 2018.…
The Financial Industry Regulatory Authority, Inc. has released frequently asked questions (FAQs) related to the enhanced confirmation disclosure requirements for certain corporate and agency debt securities transactions pursuant to recently approved amendments to FINRA Rule 2232. The new requirements obligate FINRA members to disclose additional transaction-related information to retail customers for trades in corporate or agency debt securities where the FINRA member executes on offsetting principal trade in the same security on the same day.…
On June 21, the Commodity Futures Trading Commission announced that it issued an Order of Registration to the Dubai Mercantile Exchange (DME), a Foreign Board of Trade located in the Dubai International Financial Centre. The Order of Registration allows the DME to provide direct access to its electronic order entry and trade matching system to its members and other participants located in the United States. The DME previously offered direct access to US participants pursuant…
On April 18, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued No-Action Letter 17-22, which extends relief previously granted under CFTC No-Action Letter 17-05. CFTC No-Action Letter 17-05 allowed certain swap dealers to substitute compliance with the non-centrally cleared OTC derivative margin requirements applicable in the European Union (the “EU Rules”) for compliance with certain of the CFTC’s uncleared swap margin requirements in cross-border transactions with counterparties subject to…
The Chicago Mercantile Exchange, Inc. (CME) has submitted to the Commodity Futures Trading Commission a petition for an order pursuant to Section 4d of the Commodity Exchange Act (CEA) whereby CME and its clearing members that are registered futures commission merchants would be permitted to hold, in accounts segregated in accordance with Section 4d of the CEA, Dubai Mercantile Exchange-listed positions and funds related to products in the energy sector. If granted, the order would…