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Expert Analysis

When Market Participants Receive A 'Special Call' From CFTC

Law360, New York (August 11, 2014, 10:18 AM EDT) -- On July 23, the U.S. Commodity Futures Trading Commission staff issued No-Action Letter 14-95 extending the compliance date from Aug. 15, 2014, to Feb. 11, 2016, for use of new Forms 40/40S — reports solicited from market participants by "special call" of the CFTC — and the CFTC's automated filing interface for such forms. For swap dealers and other market professionals, the relevant effective dates for similar forms have been extended into early 2015. What are these forms, and under what circumstances might a commercial entity receive such a "special call" from the CFTC?...

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