Shifting Signals, April 2025 - Relief for Swap Dealer Pre-Trade Disclosures
By EsqSocial Corporation 17/04/25
On April 4, 2025, the staff of the Commodity Futures Trading Commission ("CFTC") Market Participants Division ("MPD") issued compliance relief for registered swap dealers ("SDs") from the requirement to provide the so-called pre-trade mid-market marks ("PTMMM"). CFTC Regulation ยง 23.431 that was promulgated in 2012 under the Dodd Frank Act of 2010 mandates that SDs provide PTMMM to their non-SD counterparties to allow them to compare the PTMMM with the executable quote for the swap with the same...
By: Cadwalader, Wickersham & Taft LLP