On December 20, the CFTC issued its proposed interpretation of the term “actual delivery” in the context of how it expects to regulate retail virtual currency contracts. The deadline for public comment on the proposal is March 20, 2018. This is important because the CFTC’s interpretation will determine whether a retail customer transaction on a …
Cryptocurrency’s Legal Considerations for Asset Managers The asset management community’s interest in cryptocurrencies (also called virtual currencies) has grown in tandem with the exponential increase in market price of Bitcoin in recent months. As recently as January 2017, a single Bitcoin could be traded for $1,000. Today, a single Bitcoin traded for $16,680; a Bitcoin …
CFTC’s Modernized Record-keeping Rules Take Effect on August 28 In late May, the CFTC adopted amendments to its record-keeping rule, Rule 1.31, applicable to CFTC registrants who are obliged to keep specified records under the Commodity Exchange Act (CEA) and the CFTC’s rules. The amendments take effect on August 28. Until the amendment, CFTC rules …