According to Newsweek, Punxsutawney Phil saw his shadow on February 2, 2023, signaling 6 more weeks of winter. And, on February 24, 2023, the Financial Institution Regulatory Authority (FINRA) submitted a filing to the SEC that, in effect, will
The Derivatives & Repo Report, published by Perkins Coie LLP, focuses on legal and regulatory developments affecting derivatives and repurchase agreement (repo) markets. It covers topics such as Commodity Futures Trading Commission (CFTC) rule proposals and amendments, risk management program requirements for swap dealers and futures commission merchants, and regulatory changes impacting margin and capital requirements. The report also analyzes market events like repo rate spikes, market segmentation, and trading practices in bilateral repo markets. It provides insights into the intersection of financial regulation, market structure, and risk management relevant to financial institutions, asset managers, and market participants involved in derivatives and repo transactions.
According to Newsweek, Punxsutawney Phil saw his shadow on February 2, 2023, signaling 6 more weeks of winter. And, on February 24, 2023, the Financial Institution Regulatory Authority (FINRA) submitted a filing to the SEC that, in effect, will…
Our previous post explained the SEC’s proposal (the Proposal) to require central clearing of all “eligible secondary market transactions” with a participant in the Fixed Income Clearing Corporation (FICC). In this post we review the benefits of central…
In March 2020, we published a post entitled Master Agreements and Volatile Markets: Decline in Net Asset Value Provisions.
We believe that the March 2020 post is particularly relevant in light of the cascading nature of stock market declines…
On September 14, 2022, the SEC proposed amendments (the Proposal) to regulations for clearing agencies under the Securities Exchange Act of 1934 (the Exchange Act). The Proposal would increase the central clearing of U.S. Treasury securities, to be defined as…
This post will bring to a close, for now, our survey of the requirements of new Rule 18f-4, which investment companies must comply with by August 19, 2022. This post considers whether a Chief Compliance or Risk Officer should…
The release adopting Rule 18f-4 (the “Adopting Release”) devotes an entire section to discussing how “a fund that invests in other registered investment companies (‘underlying funds’)” should comply with the value-at-risk (“VaR”) requirements of the rule. This post considers three…
As with Fund-of-Funds, the release adopting Rule 18f-4 (the “Adopting Release”) devotes a section to sub-advised funds. We again consider three types of funds:
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This post continues our assessment of whether the Limited Derivatives User requirements of Rule 18f-4(c)(4) effectively and efficiently accomplish the SEC’s aim of providing “an objective standard to identify funds that use derivatives in a limited manner.” Here…
The financial press is awash this morning with reports that the launch of a bitcoin futures exchange-traded fund (a “BTC Futures ETF”) may be imminent.
Before recommending that clients invest directly in bitcoin or in a BTC Futures ETF, a…