Katten Muchin Rosenman

Katten is a full-service law firm with more than 600 attorneys in locations across the United States and an affiliate in London. We strive to be a firm of first choice for clients seeking sophisticated, high-value legal services nationally and globally. While Katten offers an extensive range of legal services across numerous industries, our core areas of practice include corporate, financial services, litigation, real estate, commercial finance, intellectual property and trusts and estates. Among our clients are a wide range of public and private companies, including a third of the Fortune 100, as well as a number of government and nonprofit organizations and individuals.

On December 3, the National Futures Association (NFA) proposed amendments to various NFA Compliance Rules and Interpretive Notices related to discretionary customer accounts, customer information, risk disclosures and bunched orders to apply to cleared swaps, in addition to other minor amendments. Most notably, NFA proposal would amend the following:…
The Financial Industry Regulatory Authority (FINRA) previously announced an expansion to its ongoing transparency initiative for the over-the-counter (OTC) equity market. This expansion entails FINRA publishing new data about OTC trading volume occurring outside of alternative trading systems (ATSs). As of December 2, FINRA began publishing the following types of data: 1) monthly aggregate block-size trading data for OTC trades in National Market System (NMS) stocks executed outside an ATS, on a one-month delayed basis;…
On December 4, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) issued an advisory addressing the preparation of the Chief Compliance Officer (CCO) Annual Report for futures commission merchants, swap dealers and major swap participants. The CFTC advisory discusses a number of common deficiencies that the staff has identified in its review of the 2019 CCO Annual Reports and provides additional guidance to Registrants regarding the requirements…
The Commodity Futures Trading Commission (CFTC) will hold an open meeting on December 10 at 9:00 a.m. Eastern to cover the following topics: Proposed Rule: Capital Requirements for Swap Dealers and Major Swap Participants – Reopening the Comment Period and Requesting Additional Comment Proposed Rule: Amendments to the Swap Clearing Requirement Exemption for Inter-Affiliate Swaps Proposed Rule: Settlements in Administrative and Civil Proceedings Final Rule: Amendments to Part 13 of the Commission’s Regulations (Public Rulemaking…
On December 2, the Commodity Futures Trading Commission’s (CFTC) Market Risk Advisory Committee (MRAC) announced that it will hold a public meeting at the CFTC headquarters in Washington, DC on December 11 at 9:30 a.m. Eastern. At the meeting, MRAC will receive status reports from its Climate-Related Market Risk, Central Counterparty Risk and Governance, Market Structure, and Interest Rate Benchmark Reform committees. There also will be a discussion regarding the transition from the London Inter-Bank…
On December 2, the National Futures Association (NFA) issued Notice I-19-29 reminding NFA members that any person claiming an exemption from commodity pool operator (CPO) registration under CFTC Regulation 4.13(a)(1), 4.13(a)(2), 4.13(a)(3), 4.13(a)(5), an exclusion from CPO registration under CFTC Regulation 4.5 or an exemption from commodity trading advisors (CTA) registration under 4.14(a)(8) must annually affirm the applicable notice of exemption within 60 days of the calendar year end, which is February 29, 2020 for…
On November 29, the National Futures Association (NFA) proposed an amendment to NFA Bylaw 1301(e) to reduce assessments for each order segment fee a Forex Dealer Member (FDM) submits to NFA’s Forex Transaction Reporting Execution Surveillance System (FORTRESS). Currently, each FDM is required to pay an assessment of $.004 on each order segment submitted to FORTRESS. NFA has proposed lowering the assessment to $.003, and such proposal may become effective as early as 10 days…
On December 3, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Consumer Financial Protection Bureau (CFPB) and the National Credit Union Administration (the Banking Agencies) released interagency guidance related to the use of alternative data for purposes of underwriting credit (the Guidance).…
On November 29, the UK’s Financial Conduct Authority (FCA) published a consultation paper on applying the Senior Managers Regime (SMR) to benchmark administrators. (For more information on the Senior Managers and Certification Regime, or SM&CR, please see the July 28, 2017 edition of the Corporate & Financial Weekly Digest.) SM&CR already applies to banks and insurers, and will apply to most other UK financial services firms as of December 9. Because benchmark administrators only began…