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  • ISDA derivatiViews: Deciding On Deference

    Date 27/08/2020

    In 2013, the Commodity Futures Trading Commission (CFTC) unveiled its cross-border guidance, which set out how it intended to apply US rules in foreign jurisdictions. The commission debated the meaning of a “direct and significant” impact to the US economy in order to justify a broad international application of CFTC rules. As a commissioner at that time, I made my views about the agency’s guidance very clear. I felt it went well beyond the limits set by Congress by indiscriminately exporting CFTC rules overseas with insufficient weight given to principles of international comity, creating duplication and inconsistencies in rule sets. Seven years on, the CFTC recently opted for a different approach – one that will defer to a much greater extent to foreign regulators and reduce the prospect of overseas swaps activity being subject to CFTC oversight unless it poses a material risk to the US.

  • BOX Exchange: Update To BOX Rule 7160 (Transfer Of Positions)

    Date 27/08/2020

    BOX Exchange LLC (“BOX”) recently distributed RC-2020-16 which detailed the criteria and procedures that Participants must follow in order to engage in off-floor transfers of options positions. Effective August 28, 2020, BOX has modified the criteria for certain off-floor position transfers.


  • NZX Markets To Open As Normal

    Date 27/08/2020

    NZX’s markets will open as normal today, following ongoing work to put in place additional measures to maintain system connectivity, and address the severe DDoS attacks from offshore this week.

  • Markets, Morality, And Mobsters: Remarks At The 18th Annual Corporate Governance Conference, Commissioner Hester M. Peirce, University Of Texas At Dallas Institute For Excellence In Corporate Governance, Aug. 27, 2020

    Date 27/08/2020

    Thank you Jessica [Magee].  It is a particular honor to be introduced by an SEC alumna.  Although I had hoped this could be an in-person event, I am grateful that we nevertheless can spend some time together virtually.  Before I begin, I have to remind you that the views I represent are my own and not necessarily those of the Securities and Exchange Commission or my fellow Commissioners. 

  • Adoption Of Changes To Minor Rule Violation Plans Adding CAT Reporting Compliance Rules

    Date 27/08/2020

    MIAX Exchange Group has adopted changes to the Exchanges’ Minor Rule Violation Plans (“MRVPs”) to make Members’ violations of the Consolidated Audit Trail (“CAT”) compliance rules (“CAT Compliance Rules”) eligible for disposition with a minor rule violation fine, when warranted.