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ARTICLE · 04 MAY 2011

Financial Services Alert – May 3, 2011

Goodwin Procter LLP
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As authorized under Section 1a(47)(E) of the Commodity Exchange Act (the "CEA"), as amended by Section 721 of the Dodd-Frank Act, the Department of the Treasury ("Treasury") has proposed to make a written determination that "foreign exchange swaps" and "foreign exchange forwards" (a) should not be regulated as swaps under the CEA and (b) are not structured to evade the Dodd-Frank Act in violation of any rule promulgated by the CFTC pursuant to Section 721(c) of the Dodd-Frank Act, and exempt for

United StatesFinance and Banking
Robert Kurucza
Robert Kurucza

Developments of Note

  • Treasury Proposes to Exempt Foreign Exchange Swaps and Forwards from Mandatory Central Clearing and Exchange Trading Requirements under Dodd-Frank
  • FinCEN Issues Proposed Rule Implementing Section 104(e) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
  • OCC Issues Notice of Proposed Rulemaking on Retail Foreign Exchange Transactions
  • SEC Proposes Removal of References to Credit Ratings in Rules and Forms under the 1934 Act

Briefly Noted

  • Goodwin Procter Issues Client Alert on U.S. Supreme Court Decision Upholding Provision in Consumer Contract Barring Class-Wide Arbitration
  • SEC Extends Comment Period on Rule Proposal that Would Require Exchanges to Establish Listing Standards Relating to Compensation Committees and Compensation Consultants

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