CFTC’s Evolving Disclosure Requirements

Traditionally, unlike in securities industry, transactions involving commodities and commodity derivatives have not been associated with extensive disclosures, if any.  After the Dodd Frank amendments, swap dealers are required to provide certain disclosures to their counterparties.  Recent CFTC’s enforcement actions involving disclosure requirements test the outer boundaries and the scope of required disclosures, in part with the lookback to disclosure requirements imposed by the SEC.  This seminar will discuss these requirements, emerging enforcement trends as well as developing industry responses, including in the EU and the UK.