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Commentary by Nihal Patel

The CFTC voted to adopt final rules to amend the swap dealer de minimis threshold and to propose changes to swaps trading rules. Swap Dealer De Minimis Amendments. The final rules amend the definition of "swap dealer" in CFTC Rule 1.3 in order to set the de minimis aggregate gross notional amount threshold level at $8 billion in swap dealing activity entered into by a person over the preceding 12-month period. The current rule provides for a threshold of $3 billion, subject to a "phase-in" amount of $8 billion. Swap Trading Proposals. The CFTC voted 4-1 (with CFTC Commissioner Dan M. Berkovitz

James Treanor Commentary by James Treanor

The U.S. government re-imposed sanctions on Iran that had been waived or lifted by the Joint Comprehensive Plan of Action ("JCPOA"). The announcement of hundreds of designations and prohibitions on dealings with Iran's financial, energy, shipping and other sectors completes a process which began with President Trump's May 8, 2018 decision to withdraw from the JCPOA. According to the U.S. Treasury Department ("Treasury") of Foreign Asset Control ("OFAC"), these actions are intended to prevent Iran from financing "malign activities," and place "unprecedented financial pressure" on the Iranian

Steven Lofchie Commentary by Steven Lofchie

The SEC will amend Regulation NMS Rules 600(b) and 606 to increase the transparency of broker-dealers' "handling and routing of orders in NMS stock." The amendments (i) will require a broker-dealer, upon request by a customer, to provide such customer with certain standardized disclosures related to the broker-dealer's routing and execution of the customer's "not held" orders for the previous six months, and (ii) revise the current quarterly public order-routing report to include additional disclosures regarding the terms of any payment for order flow and any profit-sharing arrangements that