Cadwalader attorneys Paul Pantano, Jonathan Flynn, Neal Kumar, Natalie Mitchell and Lamiya Rahman will host a complimentary webinar today, Wednesday, December 14, 2016. The attorneys will discuss key aspects of the final aggregation rule and the re-proposed position limits rule.
"The Risk Desk" editor John R. Sodergreen described the debate between CFTC Chair Timothy Massad and Commissioner Chris Giancarlo over an amendment to proposed Regulation Automated Trading that would allow the CFTC access to an algorithmic firm's trading source code without first issuing a subpoena.
On November 18, 2016, the CFTC will cease issuing Special Calls via the legacy Form 40/40S and begin issuing Special Calls using a new, electronic filing, submitted directly to a CFTC database (the "New Form 40/40S").
Cadwalader will host a panel on the CFTC's adopted rules on position limits for futures and swaps. The panel will discuss the proposed alternative to the designated contract markets and swap execution facility process for recognizing non-enumerated bona fide hedges, including anticipatory hedges, and for exempting certain spread transactions from speculative position limits.
Energy Metro Desk Editor John Sodergreen described the emerging debate over the CFTC's proposed Regulation Automated Trading, particularly where it concerns proposed access to source code without a subpoena.
In light of recent FINRA report cards on "spoofing," Cadwalader attorneys recommend that firms (particularly intermediaries) consider reviewing the effectiveness of their surveillance systems and their ability to detect suspicious cross-market trading patterns inside and outside the United States.