View Reports by Subject Area
View Reports by Committees
View Reports by Title

Search
advance search by committee

Committee: Futures and Derivatives

Letter to the National Futures Association (NFA) commenting on the NFA’s authority to impose a capital requirement on its commodity pool operator and commodity trading advisor members (March 2014) ( PDF format )
Subject area: Commodity Pool Operator/Commodity Trading Advisor

Letter to the SEC commenting on proposed Regulation SCI and proposed Rules 13n-6 and 822 in the context of their possible application to security-based swap data repositories (SB SDR’s) and security-based swap execution facilities (SB SEF’s) (June 2013) ( PDF format )
Subject area: Swaps

Letter to the Commodity Futures Trading Commission and Securities and Exchange Commission commenting on the use of the term “notional amount” in recent regulation and the issues arising in the calculation of “notional amount” (March 2013) ( PDF format )
Subject area: Swaps

Letter to the SEC and CFTC on proposed rules concerning swaps dealers and major swap participants (February 2011) ( PDF format )
Subject area: Swaps

Letter to the FTC urging 1) clarity with respect to eligible contract participant status and provision relating to swap position limits; and 2) temporary expemtive relief for transactions currently covered by certain Commodity Exchange Act sections (June 2011) ( PDF format )
Subject area: Swaps

Letter to the Commodity Futures Trading Commission regarding implementation of the Commission's Dodd-Frank Rules (June 2011) ( PDF format )
Subject area: Exemptive Relief

Letter to the FTC commenting on proposed rulemaking regarding federal speculative position limits applicable to exempt and agricultural commodities (April 2011) ( PDF format )
Subject area: Independent Account Controllers

Comments to the FTC and SEC on proposed rulemaking under the Dodd-Frank Wall Street Reform and Consumer Protection Act ( November 2010) ( PDF format )
Subject area: Swaps

Letter to the CFTC commenting on the CFTC's proposed rulemaking under the Dodd-Frank Wall Street Reform and Consumer Protection Act (September 2010) ( PDF format )
Subject area: Swaps

Letter to congress regarding the Over-the-Counter Derivatives Markets Act of 2009 (October 2009) ( PDF format )
Subject area: Derivatives

Letter to the Federal Trade Commission commenting on the revised proposals concerning the prohibitions on market manipulation and false information in Subtitle B of the Energy Independence and Security Act of 2007 (May 2009) ( PDF format )
Subject area: Anti Manipulation Rule

Comments on Swap Hedge Exemption Concept Release (May 2009) ( PDF format )
Subject area: Hedge Exemption

Letter to the Commodity Futures Trading Commission regarding the Commission’s proposal to amend its governing commodity pool operator periodic account statements and annual financial reports (March 2009) ( PDF format )
Subject area: Commodity Pool

Letter to the Commodity Futures Trading Commission expressing concerns about the proposed amendments to Commission rules 4.26 and 4.36 concerning the electronic filing of disclosure documents by commodity pool operators and commodity trading advisors ( PDF format )
Subject area: Electronic Filing

Letter to the Federal Trade Commission offering comments on a proposal by the FTC regarding market manipulation and false information (October 2008) ( PDF format )
Subject area: Market Manipulation

Letter to the Federal Trade Commission commenting on the proposals concerning the prohibitions on market manipulation and false information in Subtitle B of the Energy Independence and Security Act of 2007 ( PDF format )
Subject area: Anti Manipulation Rule

Comments submitted to the National Association of Securities Dealers expressing concerns with Notice to Members 07-27, Member Private Offerings ( PDF format )
Subject area: Private Offerings

Letter commenting on a proposed new risk-based capital adequacy framework (CAF) ( PDF format )
Subject area: Capital Adequacy Framework

Letter to the Commodity Futures Trading Commission commenting on whether there are any conflicts between the criteria and relief in Advisory 18-96 and Commission Regulation 4.13(a)(4), Electronic Filing of Part 4 Exemptions ( PDF format )
Subject area: Electronic Filing

Letter to the North American Securities Administrators Association (NASAA) commenting on the proposed revisions to the Guidelines for Commodity Pool Programs ( PDF format )
Subject area: Commodity Pool

Letter to the Commodity and Futures Trading Commission expressing support for the proposal to amend the rules governing advertising by commodity pool operators, commodity trading advisors ( PDF format )
Subject area: Commodity Trading Advisor, Advertising by

Letter to the Commodity Futures Trading Commission in support of the Commission's proposal to define the term "client" of a commodity trading advisor in a new Commission rule ( PDF format )
Subject area: Commodity Trading Advisor

Letter to the SEC regarding proposed rule changes by the NASD relating to the implementation date of notice to members ( PDF format )
Subject area: Trail Commissions

Letter to the SEC regarding the notice of filing and immediate effectiveness of proposed rule changes relating to the treatment of commodity pool trail commissions ( PDF format )
Subject area: Trail Commissions