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June 18, 2020, Covington Alert
April 6, 2020, Covington Alert
On March 24, 2020, the CFTC unanimously voted to adopt final interpretive guidance on when “actual delivery” of retail commodity transactions in virtual currencies occurs within the meaning of Section 2(c)(2)(D) of the Commodities Exchange Act, making them eligible to meet the exception from regulation as a futures contract. The CFTC previously published ...
March 18, 2020, Covington Alert
On March 17, 2020, the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) and Division of Market Oversight (DMO) each released an announcement regarding a series of no-action letters in response to the ongoing global COVID-19 pandemic (see here for the DSIO announcement and here for the DMO announcement). The ...