The CFTC proposal marks an important step in expanding access to non-U.S. derivatives exchanges to U.S. market participants.
Currently, FBOTs are permitted to grant direct trading access to U.S. FCMs, CPOs and CTAs to place orders for their customers (or for commodity pools, in the case of CPOs). However, FBOTs are not currently permitted to grant direct trading access to U.S. IBs. The proposal would fill this gap by permitting FBOTs to grant direct trading access to U…
This is a significant proposal that will permit broker-dealers acting as placement agents in offerings of private funds to QPs under Section 3(c)(7) of the Investment Company Act to include projections and targets in fund marketing materials. This represents a significant liberalization of the current regime which prohibits investment projections in broker-dealer communications except in the very limited circumstances, and prohibits target returns in communications to non-“…
While one may be sympathetic to the notion that a temporary no-action letter should not have a permanent life — and it is good of the director to provide substantial advance notice of the expiration of the SEC's no-action letter to SIFMA — it is still reasonable to ask, "Why should the letter expire?" Insofar as broker-dealers produce research, they are subject to a very substantial body of regulation. It is not obvious that there is any benefit in forcing broker-dealers to also…
This proposal is part of FINRA's ongoing efforts to bring greater transparency to bond market transactions. In this case, the proposal addresses two types of transactions in which the reported price may not reflect the current market price. The issue for market participants is whether the benefits of obtaining additional information as to these types of transactions warrants the additional implementation costs. TRACE reporting is fertile ground for enforcement action. The more information…
Recent Articles & Comments
The CFTC proposal marks an important step in expanding access to non-U.S. derivatives exchanges to U.S. market participants.
Currently, FBOTs are permitted to grant direct trading access to U.S. FCMs, CPOs and CTAs to place orders for their customers (or for commodity pools, in the case of CPOs). However, FBOTs are not currently permitted to grant direct trading access to U.S. IBs. The proposal would fill this gap by permitting FBOTs to grant direct trading access to U…
This is a significant proposal that will permit broker-dealers acting as placement agents in offerings of private funds to QPs under Section 3(c)(7) of the Investment Company Act to include projections and targets in fund marketing materials. This represents a significant liberalization of the current regime which prohibits investment projections in broker-dealer communications except in the very limited circumstances, and prohibits target returns in communications to non-“…
While one may be sympathetic to the notion that a temporary no-action letter should not have a permanent life — and it is good of the director to provide substantial advance notice of the expiration of the SEC's no-action letter to SIFMA — it is still reasonable to ask, "Why should the letter expire?" Insofar as broker-dealers produce research, they are subject to a very substantial body of regulation. It is not obvious that there is any benefit in forcing broker-dealers to also…
This proposal is part of FINRA's ongoing efforts to bring greater transparency to bond market transactions. In this case, the proposal addresses two types of transactions in which the reported price may not reflect the current market price. The issue for market participants is whether the benefits of obtaining additional information as to these types of transactions warrants the additional implementation costs. TRACE reporting is fertile ground for enforcement action. The more information…