ARTICLE
6 October 2016

Swap Dealer Settles Charges Of Failure To Submit Accurate Large Trader Reports (With Cadwalader Memorandum)

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The CFTC fined a provisionally registered swap dealer ("SD") for submitting inaccurate large trader reports ("LTRs") for physical commodity swap positions.
United States Finance and Banking

The CFTC fined a provisionally registered swap dealer ("SD") for submitting inaccurate large trader reports ("LTRs") for physical commodity swap positions.

The CFTC Order stated that the LTRs contained multiple errors, including missing data and data presented in a format inconsistent with CFTC requirements.

The CFTC Order required the SD to pay a $400,000 civil monetary penalty and cease and desist from further violations of the specified regulations.

In a relevant  memorandum, Cadwalader attorneys Paul Pantano, Anthony Mansfield, Jonathan Flynn and Natalie Mitchell analyzed the CFTC's "trend toward more aggressive enforcement" of violations of the Swaps LTR rule, and provided a summary of recent CFTC penalties for these violations. The memorandum notes that "compliance professionals should continue to review their reporting processes, including Swaps LTR, to confirm that they conform to CFTC rules."

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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