CDS CDS
Swaps and CDS

November 20, 2012
Treasury Issues Determination Exempting Foreign Exchange Forwards and Foreign Exchange Swaps (Sullivan & Cromwell).

October 15, 2012
CFTC Relief and Guidance as the "Swap" Definition Takes Effect (Sullivan & Cromwell).

September 4, 2012
Clearing Exemption for Inter-Affiliate Swaps: CFTC Proposes Rule to Exempt Swaps between Certain Affiliated Entities from the Clearing Requirement under Dodd-Frank (Sullivan & Cromwell).

August 13, 2012
CFTC’s Final Rules Definition of Swap, Security-Based Swap, and Security-Based Swap Agreement.


August 10, 2012
An Overview of Dodd-Frank’s Treatment of Loan-Based Swaps (Richards Kibbe & Orbe).

August 6, 2012
The Effect of Bankruptcy on an Out-of-the-Money Swap (Richards Kibbe & Orbe).


July 12, 2012
CFTC Guidance on Extraterritoriality: CFTC Releases Proposed Guidance on and Exemptive Relief from Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act (Sullivan & Cromwell).

July 11, 2012
SEC and CFTC Adopt Product Definitions Under Title VII of Dodd-Frank: The SEC and CFTC Voted to Further Define “Swap”, “Security-Based Swap”, and “Security-Based Swap Agreement” and Finalize Related Requirements; CFTC Finalizes End-User Exception (Sullivan & Cromwell).

July 9, 2012
OCC Revises Lending Limits Rule to Include Derivatives and Securities Financing Transactions (Cleary Gottlieb).

July 3, 2012
Implementation of Security-Based Swap Regulations under Title VII: SEC Proposes Statement of General Policy on the Sequencing of Compliance with Security-Based Swap Regulations (Sullivan & Cromwell).

June 27, 2012
OCC Issues Interim Final Rules Applying the Lending Limit for National Banks and Savings Associations to the Credit Exposure to Derivatives and Securities Financing Transactions (Sullivan & Cromwell).

June 8, 2012
CFTC and SEC Issue Final Swap-Related Rules Under Title VII of Dodd-Frank (Sullivan & Cromwell).

May 14, 2012
CFTC Proposes Order Amending Effective Date for Swap Regulation to December 31, 2012 (or until the CFTC's rules and regulations go into effect, whichever is sooner).

April 12, 2012
What is a Swap?  Maybe (Almost) Everything? You Gotta Problem with That? (Cadwalader Wickersham & Taft).

April 10, 2012
New Pan-European Restrictions on Short Selling (Cadwalader, Wickersham & Taft).

March 30, 2012
Clarification of the Swaps Push-Out Effective Date (Sullivan & Cromwell).

February 6, 2012
CFTC Imposes External Business Conduct Standards on Swap Dealers and Major Swap Participants (Sullivan & Cromwell).

Clifford Chance International Regulatory Update.

CFTC and SEC Release Joint Report to Congress on International Swap Regulation.

January 13, 2012
CFTC Issues Final Order Amending Effective Date for Swap Regulation.

November 28, 2011
European Parliament Votes to Ban “Naked” Credit Default Swaps on Sovereign Debt and Restrict “Naked” Short Sales (Paul Weiss).

November 10, 2011
CFTC Adopts Position Limits Rule, Proposes to Extend Temporary Exemptive Relief From the Applicability of Certain Swap Provisions of the Dodd-Frank Act (Paul Weiss).

October 26, 2011
CFTC Extended Relief with Respect to Dodd-Frank Effective dates for Derivatives (Shearman & Sterling).

October 25, 2011
CFTC Amended Order.

September 21, 2011
Proposed Treasury Regulations Regarding Swaps and Other Notional Principal Contracts (Cadwalader, Wickersham & Taft).

July 22, 2011
LSTA Week in Review.

July 19, 2011
CFTC Order.

July 15, 2011
SEC Proposed Rule: Business Conduct Standards (Cleary Gottlieb).

Title VII Provisions in Dodd-Frank Become Effective on July 16 (LSTA).

July 5, 2011
Global Trade Associations Warn of Potential Pitfalls of New Derivatives Regulations (Cadwalader, Wickersham & Taft).

June 29, 2011
Clifford Chance International Regulatory Update.

June 24, 2011
MSHDA v. Lehman: Trying to Keep the Safe Harbor Safe for Swap Counterparties (Richards Kibbe & Orbe).

June 17, 2011
CFTC Order Extending Certain Provisions in Title VII of the Dodd-Frank Act.

CFTC, SEC Propose to Delay the Applicability of Certain Swap Provisions of the Dodd-Frank Act (Paul Weiss).

June 15, 2011
SEC Order Extending Certain Provisions in Title VII of the Dodd-Frank Act.

June 13, 2011 
Two Dodd-Frank Problems: the Effective Date and the Definitions Contingency Planning in the Absence of a Regulatory Structure (Cadwalader, Wickersham & Taft).

May 24, 2011
Report on Sovereign CDS.

May 18, 2011
Department of Treasury Proposes to Exempt FX Swaps and FX Forwards from the Definition of “Swap” under the Commodity Exchange Act (Paul Weiss).

May 12, 2011
U.S. Treasury Proposes FX Swap and Forward Exemption Under Dodd-Frank (Cleary Gottlieb).

May 2, 2011
Regulators Propose Margin and Capital Requirements for Non-Cleared Swaps (Dewey & LeBoeuf).

April 29, 2011
US Banking Regulators Propose Capital and Margin Requirements for Covered Swap Entities.

April 28, 2011
CFTC Proposed Rules and Interpretative Guidance Regarding Swaps.

April 27, 2011
CFTC Proposes Uncleared Swap Margin Requirements (Cleary Gottlieb).

Dodd-Frank: CFTC and Prudential Regulators Release Proposed Margin Requirements for Uncleared Swaps (Shearman & Sterling).

April 14, 2011
Prudential Regulators Propose Swap Margin and Capital Requirements (Cleary Gottlieb).

April 13, 2011
CFTC, Prudential Regulators Propose Margin Rules for Non-Cleared Swaps (Cadwalader, Wickersham & Taft).

March 10, 2011
EU States Divided Over Curbs on Debt Swaps (Financial Times).

March 9, 2011
EU States Fail to Agree CDS Shortselling Rules (Reuters).

February 14, 2011
Proposed EU “Bail-in” Measures May Impact Credit Derivatives Framework (Cadwalader, Wickersham & Taft).

January 10, 2011
CFTC and SEC Propose Further Definitions of “Swap Dealer” and “Major Swap Participant” (Paul Weiss).

October 1, 2010
Loan CDS and TRS: Life After Dodd-Frank? (Richards Kibbe & Orbe).

June 26, 2009
LSTA Week in Review.

June 24, 2009
Recently Proposed Regulatory Reforms to Over-The-Counter (“OTC”) Derivatives and Securitization Markets (Paul Weiss).

April 8, 2009
ISDA Auction Hardwiring and other Market Initiatives: Strengthening the Infrastructure for CDS Transactions (Cadwalader, Wickersham & Taft).

March 24, 2009
The Big Bang Protocol and A New Structural Framework for Credit Default Swaps (Paul Weiss).The Big Bang Protocol and A New Structural Framework for Credit Default Swaps (Paul Weiss).

March 20, 2009
Just Two CDS Clearinghouses Will Survive, Analysts Say.

March 18, 2009
ICE Clears Major Hurdle for CDS.

March 13, 2009
Understanding the New Standard North American Credit Default Swap (Richards Kibbe & Orbe).

ISDA Auction Hardwiring and other Market Initiatives: Strengthening the Infrastructure for CDS Transaction (Cadwalader, Wickersham & Taft).

March 9, 2009
ICE Starts Credit-Default Swap Clearing in Bid for $400 Million.

March 5, 2009
ISDA Publishes Close-Out Amount Protocol.

February 20, 2009
Regulators Seek Coordinated Oversight of CDS Clearinghouses (Wall Street Journal).

LSTA Week in Review.

February 19, 2009
A Global Framework for Cooperation Among CDS CCP Regulators (FRBNY).

February 6, 2009
CDS Market Changes (Barclays Capital).

February 2, 2009
Draft U.S. Law Seeks to Regulate Credit Default Swaps (Cadwalader, Wickersham & Taft).

January 28, 2009
The Game Changer (George Soros).

January 25, 2009
Everything You Wanted to Know about Credit Default Swaps-but Were Never Told (Peter J. Wallison).