To provide an overview of the Commodity Futures Trading Commission’s (CFTC’s) new self-reporting and cooperation program.
Summarizes the key features of the CFTC’s new cooperation program and the CFTC’s statement of its purpose in enacting the program; provides the authors’ views on the likely implications of the program for CFTC enforcement actions.
Whether the CFTC’s self-reporting and cooperation program will be a useful tool for deterring misconduct remains to be seen as the CFTC begins to implement it, but there are indications that it may encourage cooperation. If properly implemented, the program has the potential to benefit the CFTC and regulated parties significantly.
Practical insights on a new CFTC policy from experienced civil enforcement lawyers.
