spacer

Is this email not displaying correctly?

View it in a web browser

spacer

Promontory Financial Group

spacer

 

March 28, 2012

The Commodity Futures Trading Commission (“CFTC”) has published final Business Conduct Standards for Swap Dealer and Major Swap Participants that require that Swap Dealers and Major Swap Participants have a “reasonable basis” to believe that the Special Entities, including Federal agencies, state and local governments, certain pension plans and endowments, with which they engage in swaps transactions have representatives that are both “qualified” and “independent.” It is expected that, in order to meet this obligation, many Swap Dealers and Major Swap Participant will take advantage of a safe harbor which allows them to rely on a written representation from a Special Entity counterparty that its representative is independent and qualified. In order to make such representations, Special Entities should establish a control framework, including written policies and procedures, to ensure that any such representations are accurate when made and during the life of the relationship. Failure to do so may effectively preclude the Special Entity from engaging in swaps transactions.

Click here to read the full brief >>  

spacer
 

You are receiving this e-mail because Promontory Financial Group wishes to keep you informed of important policy and regulatory developments. If you would prefer not to receive similar emails, please e-mail us at newsletter@promontory.com, and we will remove you from our correspondence list.

You may also write to us at:
Promontory Financial Group, L.L.C.
801 17th Street, N.W.
Suite 1100
Washington, DC 20006

Copyright © 2012 Promontory Financial Group. All rights reserved.

spacer