Exchanges and Clearing Organizations

Sidley represents securities, futures and options exchanges and clearing organizations in connection with their regulatory and transactional matters.

Representative transactions include obtaining contract market designation and derivatives clearing organization status for a start-up futures exchange, assisting foreign futures exchanges in obtaining approval to place terminals in the United States and to offer non-U.S. futures contracts on stock indexes to U.S. investors, representation of a national securities exchange in connection with its securities listings programs and other matters involving both Federal and state securities laws.

We represent securities and futures clearing organizations in connection with every aspect of their operations, including obtaining regulatory approval of new products and innovative programs such as cross-margining arrangements between securities and futures products and links with foreign exchanges.

Our practice involves frequent contact with the Division of Market Regulation of the Securities and Exchange Commission and the Commodity Futures Trading Commission’s Divisions of Market Oversight and Clearing and Intermediary Oversight. We are involved in the creation of new electronic markets and in many aspects of the fundamental restructuring of the world’s financial markets currently underway.

• U.S. Congress Enacts JOBS Act, Increasing 499 Investor Limit for Private Funds to 1,999 and Eliminating Prohibition Against General Solicitation in Connection with Certain Private Offerings
  March 28, 2012
• SEC Adopts Revised Qualified Client Standards for Performance Fees Under the Advisers Act
  July 15, 2011

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• Futures-Based Exchange-Traded Funds - What are They, How are They Structured and Who Regulates Them?
  October 2011
• Clearing OTC derivatives: the Dodd-Frank Act and the new EU Regulation
  2011