FAQs about ICE Releases new Wash Trades This month the Intercontinental Exchange (aka ICE) released a revised Wash Trade FAQ document. This isn’t simply arbitrary guidance. It comes after considerable review with the CFTC, who list it along with the previous edition on their site. The last version was issued a little over 6 years ago […]
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Your End-User Dodd-Frank Checklist In Texas it’s illegal to graffiti someone’s cow. Seriously, you can’t make this stuff up. So at some point someone in Texas took branding a bit too far. And a legislature got into a knot and viola we have a law. Speaking of fun laws, Dodd-Frank is upon us. Here is
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The CFTC issued some breaks by laying out a series of Dodd Frank “No-Action” letters. The biggies: CFTC issued a No-Action letter to prevent firms from crossing into Swaps Dealer status. The rule states that any firm doing more than $25 Million in business with “Special Entities” such as a Federal, State or Local utility
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Dodd-Frank Position Limits CFTC sent back home to do its homework. The District Court tossed the position limits ruling. Don’t get me wrong. I really feel for the gauntlet that the CFTC has been put through in terms of getting out new rules. But the District Court found that the organic legislation did not give
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Last week ICE announced that it is registering its products as Futures. ICE has always traded “look alike” swaps that acted and behaved just like futures. As look-alike contracts, ICE was able to stay out of the Commodity Exchange Act and the CFTC. Dodd Frank changed all of that. So ICE seems to have adopted
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Dodd Frank | Trade Vault and DTCC “Gotchas” The compliance deadlines are looming. Some of the bigger Gotchas that keep coming up: Data Is Not In Our Trading System. The CFTC wants (XYZ Data Point). We don’t have that in our trading system! Case in Point: Option Expiration Time Zone. Obscure, yes. So much so
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Regulatory | Trick Bites Back! One of our gripes with trading systems is that sometimes they just can’t properly book certain trade types. Yes, there really are trading systems out there that can’t book Futures. Yes, there really are systems out there that can’t book spread trades, options and an assortment of exchange products upon
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