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Managing the Risk: An Overview of CFTC Swap Dealer Enforcement Actions under Dodd-Frank  

Author:  Anne M. Termine.; Uttara Dukkipati.; B. Graves Lee.

Source: Volume 53, Number 17, October 1 2020 , pp.201-209(9)

Review of Securities & Commodities Regulation

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In the decade since the passage of the Dodd-Frank Act, the CFTC has brought 28 enforcement actions against swap dealers. The authors describe these actions in the categories of reporting, recordkeeping, risk management, business conduct, and supervision. They then turn to traditional enforcement actions, discussing spoofing, market manipulation, and fraudulent misrepresentation. They close with a note on the CFTC’s recent issuance of proposed rules that would amend certain reporting requirements for swap dealers and management of cross-border activity.

Keywords: Dodd-Frank Title VII; Swap Data Reporting; Risk Management; Business Conduct Standards; Failure to Supervise; Spoofing; Market Manipulation; Fraudulent Misrepresentation

Affiliations:  1: Covington & Burling LLP; 2: Covington & Burling LLP; 3: Covington & Burling LLP.

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