Category Archives: Regulation

CFTC Approves Supplemental Proposal for Proposed Regulation AT

By: Athena Eastwood, Anthony Mansfield, Paul Pantano, Neal Kumar, Natalie Mitchell and Lamiya Rahman On November 4, 2016, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) approved, by a 2 – 1 vote, a supplemental proposal (“Reg AT Supplemental Proposal”) that amends a 2015 proposed … Continue reading

Posted in CFTC, Commodity Trading

Not Your Grandmother’s Form 40

By Athena Eastwood, Anthony Mansfield, Paul Pantano, Neal Kumar and Natalie Mitchell A common tool that the Commodity Futures Trading Commission (“CFTC” or the “Commission”) relies upon to conduct market surveillance, including monitoring compliance with position limits, will soon enter the digital age – the … Continue reading

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

FERC Issues ANOPR on Revisions to Oil Pipeline Indexing Policies and Reporting Requirements

By Mark Haskell, Brett Snyder and Lamiya Rahman On October 20, 2016, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued an advanced notice of proposed rulemaking (“ANOPR”) seeking comments on potential revisions to (1) the Commission’s policies for evaluating oil pipeline indexed … Continue reading

Posted in FERC, Oil & Gas, Regulation

CFTC Issues Fourth Penalty for Inaccurate Large Trader Reporting of Swaps

By Anthony Mansfield, Paul Pantano, Jonathan Flynn and Natalie Mitchell On September 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC” or the “Commission”) issued a fourth penalty for violations of its Swaps Large Trader Reporting (“Swaps LTR”) rule.  This time, the penalty was … Continue reading

Posted in CFTC, Commodity Trading, Regulation

CFTC Staff Issues Final Swap Dealer De Minimis Exception Report

By Athena Eastwood, Anthony Mansfield, Paul Pantano and Neal Kumar On August 15, 2016, Staff of the U.S. Commodity Futures Trading Commission (“CFTC”) published a final report regarding the de minimis exception from swap dealer registration (“Staff De Minimis Report”).  The Staff De Minimis … Continue reading

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

CFTC Issues $560,000 Penalty for Inaccurate Large Trader Reporting of Swaps

By Anthony Mansfield, Jonathan Flynn, Neal Kumar and Michael Selig On July 6, 2016, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) fined Barclays Bank PLC (“Barclays”) $560,000 for inaccurate large trader reporting of swaps positions.  This is the third and largest civil … Continue reading

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

FERC Issues Order Assessing Civil Penalties Against ETRACOM

On Friday, June 17, 2016, the Federal Energy Regulatory Commission (the “Commission”) issued an Order Assessing Civil Penalties against ETRACOM LLC (“ETRACOM”) and ETRACOM’s founding member and majority owner, Michael Rosenberg (together, “Respondents”). The Commission held that the Respondents violated … Continue reading

Posted in Enforcement and Investigations, FERC, Oil & Gas, Power, Regulation

D.C. Circuit Upholds FERC’s NEPA Analysis in Sabine Pass and Freeport LNG Projects

On June 28, 2016, the U.S. Court of Appeals for the District of Columbia Circuit rejected two related challenges to the Federal Energy Regulatory Commission’s environmental review of the Sabine Pass LNG and Freeport LNG applications to site, construct, and … Continue reading

Posted in Cases, Enforcement and Investigations, LNG, Oil & Gas, Power, Regulation

FERC Issues Order Clarifying Reporting Requirements in the Electric Quarterly Report and Updating Data Dictionary

On June 16, 2016, the Federal Energy Regulatory Commission issued an order implementing specified clarifications to existing Electric Quarterly Report (“EQR”) reporting requirements and the accompanying EQR Data Dictionary.  The Commission’s order revised or affirmed the following reporting requirements and … Continue reading

Posted in Enforcement and Investigations, Power, Regulation

CFTC Holds Roundtable to Consider Proposed Regulation AT

By Gregory Mocek, Paul Pantano, Neal Kumar, Michael Selig, and Mary Treanor On June 10, 2016, Staff for the Commodity Futures Trading Commission (“CFTC”) held a public roundtable to discuss its proposed Regulation Automated Trading (“Regulation AT”).  The CFTC proposed Regulation AT in an attempt … Continue reading

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