Search Results: Derivatives

Ding, Dong! The Dealer/Trader Distinction is Dead. HFTs and DEX AMMs Should Take Notice

The SEC recently proposed rules that would greatly expand the Exchange Act definition of “dealer” and essentially kill the existing dealer/trader distinction long-recognized by the SEC.  The likely outcome is that most proprietary trading firms will need to register with the SEC as dealers and become members of FINRA or…

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SEC Proposes Rules that Could Regulate DeFi, Extend to Aspects of Centralized Crypto Exchanges

Here is a link to our client alert addressing the SEC’s proposed change to the “exchange” definition, including introduction of the new term “communication protocol system.” There were zero references to crypto, blockchain, DeFi, or distributed ledger technology in the 654-page proposal. Nevertheless, the proposal makes clear that it applies…

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CFTC Announces New Climate Risk Unit — the “CRU”

On March 17, 2021, Acting CFTC Chairman Rostin Behnam announced that the derivatives regulator had established a new interdivisional group called the Climate Risk Unit or the “CRU” to focus on the derivatives markets’ role in addressing climate-related risk and transitioning to a low-carbon/net-zero economy.  The CRU (sounds like an…

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