January 24, 2021

Volume XI, Number 24


January 22, 2021

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New FAQs Published Regarding the Post-Trade Name Give-Up Rule in CFTC Regulation 37.9(d)

The Commodity Futures Trading Commission has published certain FAQs prepared by the Division of Market Oversight (DMO) in response to questions from market participants on the post-trade name give-up rule prior to the November 1 compliance date. The new FAQs address certain aspects of compliance with the rule with respect to: “made available for trade” (MAT) swaps that are packaged with non-MAT swaps; voluntarily cleared non-MAT swaps; and swaps rejected by processing systems because the LEIs on either side of the trade are matching.

Further discussion of the new FAQs is available here.


©2020 Katten Muchin Rosenman LLPNational Law Review, Volume X, Number 311



About this Author

Kevin M. Foley, Finance Lawyer, Katten Llaw Firm

Kevin M. Foley has extensive experience in commodities law and advises a wide range of clients, both in the United States and abroad, on compliance with the Commodity Exchange Act and the rules of the Commodity Futures Trading Commission (CFTC) affecting traditional exchange-traded products, as well as the over-the-counter markets involving swaps and other derivative instruments. His clients include futures commission merchants, derivatives clearing organizations, designated contract markets, foreign boards of trade and an industry trade association.


Elizabeth Organ Financial Markets and Funds Katten Muchin Rosenman New York, NY

Elizabeth Organ represents clients across the financial services industry, with a focus on regulatory compliance and advice. Liz's background positions her to provide valuable legal counsel on transactional and regulatory matters relating to commodities and derivatives, investment management, and cryptoassets and distributed ledger products.

Helping clients address complex regulatory and legal challenges

Liz assists clients with a range of financial services regulatory matters, collaborating with legal staff, business executives and regulators alike to pursue...