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CPO/CTAs

Comment period reopened for certain SD repository and data reporting requirements
The Commission is also proposing revisions to streamline the requirements for reporting new swaps
The Commission is also proposing revisions that, among other things, change the “block trade” definition
These matters are currently the subject of relief in certain no-action letters from Commission staff
Depending on who you listen to, the proposal either ignores Congress’ intent or makes common sense
The existing framework is largely a historical remnant of an approach that predates cash-settled futures contracts
The SRO provides two steps to check on registration/exemption status
The amendments address certain risk management and reporting obligations
Gain greater insight into how to do your break-even analysis for the NFA
You're directed to report “if your cloud service providers have been affected by this attack"
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