Category Archives: Commodity Trading

A Signal of Things to Come? New CME Rule 512 Reflects Modified Stance for Violations of Futures and Options Reporting Requirements

By Athena Eastwood, Gregory Mocek, Jonathan Flynn, Neal Kumar and Mary Treanor. On March 24, 2015, the CME Group, Inc. (“CME”) announced a proposed amendment to Rule 512 indicating that it will impose a minimum fine of $1,000 for repeat violations of its exchanges’ reporting … Continue reading

Posted in CFTC, CME, Commodity Trading, Enforcement and Investigations, Mining/Metals, Oil & Gas, Power, Regulation

Unregistered CTA Summit Energy Services: Choose Your Words Wisely

By Athena Eastwood, Gregory Lawrence, Andrew Greenberg, and Neal Kumar A recent case highlights the importance of periodically reviewing an energy company’s marketing materials and related activities (including statements made on websites) to ensure that the company is not holding itself out — … Continue reading

Posted in Cases, CFTC, Commodity Trading, Mining/Metals, Oil & Gas, Power, Regulation

New Exchange Rules on Disruptive Trading Practices Summary Chart

By Athena Eastwood, Anthony Mansfield, Gregory Mocek, Paul Pantano, Sohair Aguirre, Isabelle Corbett, Jonathan Flynn, Neal Kumar On January 14, 2015, the Intercontinental Exchange (“ICE”) rule prohibiting disruptive trading practices (ICE Rule 4.02) became effective.  The ICE Rule is substantively the same as Rule 575 passed by … Continue reading

Posted in CME, Commodity Trading, ICE, Mining/Metals, Oil & Gas, Power, Regulation

The Fate of Demand Response Hangs in the Balance

By Gregory Lawrence, Sohair Aguirre, Natalie Mitchell and Lamiya Rahman The Justices of the United States Supreme Court are not strangers to the retail versus wholesale distinction that often plagues FERC’s regulations.  Indeed, on January 12, 2015 they heard arguments in Oneok v. Learjet … Continue reading

Posted in Cases, Commodity Trading, FERC, Oil & Gas, Power, Regulation, Supreme Court

New MiFID I Consultation Paper Creates Further Challenges for Commodity Market Participants

By Assia Damianova, Doron Ezickson, Nick Shiren, Jonathan Flynn, Antoinette Maginness and Adam Topping On 29 September 2014, ESMA published a consultation paper (the Consultation Paper) seeking industry feedback for guidelines relating to certain commodity derivatives, namely those falling under C6 and C7 of Annex I … Continue reading

Posted in Commodity Trading, EMIR, Enforcement and Investigations, MiFID, Oil & Gas, Power, Regulation

First Criminal Prosecution for Spoofing: High Frequency Trading Firm Owner Indicted in Northern District of Illinois

By Jodi Avergun, Anthony Mansfield, Gregory Mocek, Paul Pantano, Isabelle Corbett and Jonathan Flynn On October 2, 2014, the U.S. Attorney for the Northern District of Illinois announced the indictment of Michael Coscia, the owner of Panther Energy Trading (“Panther”), for six counts of commodities fraud … Continue reading

Posted in Cases, CFTC, Commodity Trading, Enforcement and Investigations, Mining/Metals, Oil & Gas, Power, Regulation

Update to New CME Rule on Disruptive Trading Practices Summary Chart

By Anthony Mansfield, Paul Pantano, Sohair Aguirre and Neal Kumar On August 28, 2014, the Chicago Mercantile Exchange Inc., the Board of Trade of the City of Chicago, the New York Mercantile Exchange, Inc., and the Commodity Exchange, Inc. (collectively, the “CME”) submitted a … Continue reading

Posted in CFTC, Commodity Trading, Oil & Gas, Regulation

New CME Rule on Disruptive Trading Practices Summary Chart

By Anthony Mansfield, Paul Pantano, Sohair Aguirre and Neal Kumar On August 28, 2014, the Chicago Mercantile Exchange Inc., the Board of Trade of the City of Chicago, the New York Mercantile Exchange, Inc., and the Commodity Exchange, Inc. (collectively, the “CME”) submitted a … Continue reading

Posted in CFTC, Commodity Trading, Enforcement and Investigations, Regulation

Summary of Prudential Regulators’ Re-Proposed Margin Rules

By Steven Lofchie, Jeffrey Robins and Nihal Patel On September 3, the Board of Governors of the Federal Reserve System (“Board”), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration and the Federal Housing Finance … Continue reading

Posted in CFTC, Commodity Trading, Dodd-Frank, Enforcement and Investigations, Regulation

REMIT Draft Implementing Acts Further Define Data Reporting Obligations

By Doron Ezickson and Adam Topping On 8 July 2014, the European Commission’s DG Energy published an updated draft of the implementing acts on data reporting under the Regulation on Wholesale Energy Market Integrity and Transparency (“REMIT”). This document sets out the … Continue reading

Posted in Commodity Trading, Oil & Gas, Power, Regulation, REMIT