CBOE Boards the Cryptocurrency Train

Julianne DardanesFirm News, Market Rules & Responsibilities0 Comments


On August 2nd, the Chicago Board Options Exchange (CBOE) launched itself into the Bitcoin market worth tens of billions of dollars via an announcement that left many of the cryptocurrency’s users jumping for joy. This announcement revealed that the CBOE has entered into an exclusive global license with Gemini Trust Company to use Gemini’s Bitcoin market data to create new indices and to redistribute Gemini’s market data over the CBOE’s market data feeds. The CBOE also plans to use Gemini’s data to develop Bitcoin futures, which it expects to list on the CBOE Futures Exchange (CFE) in late 2017 or early 2018.

CFTC and SEC Issues

The implications of this announcement are huge; with the CBOE in the market, cryptocurrency futures will now be traded on a well-known and heavily regulated global exchange. Still, the CBOE will have to jump through some regulatory hoops to put its plan into action. Gemini Trust made headlines back in March when the SEC rejected a request from Better Alternative Trading System (BATS) to make a rule change that would have allowed for a Winklevoss Bitcoin Trust Exchange Traded Fund (ETF) listing on BATS. At that time, the SEC asserted its belief that significant markets for Bitcoin were not up to par as far as regulation goes and that as such, the ETF listing for Gemini Trust would not meet the requirements necessary under the Securities Exchange Act of 1934. To date, the SEC and CFTC have not commented on the CBOE’s August 2nd announcement.

Although Bitcoin fans are cheering this recent decision, it remains to be seen what regulatory hurdles may be thrown at the CBOE and the cryptocurrency market as a whole.



FinTech Events, Chicago Style

Jess GoodwinFirm News0 Comments


FinTech is an umbrella term for technology innovation that disrupts trading, banking, insurance, and more in the financial services industry. From hedge funds and startups to big banks, Chicago has a deep bench of FinTech businesses collaborating and competing to create the most efficient financial services. The city has embraced FinTech’s expanding role in its already robust financial services industry by offering a plethora of events for businesses and individuals in the space.
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Fundraising While Female: Crowdfunding Campaigns vs. Seeking Venture Capital

WebContentFirm News0 Comments


When growing and fundraising for a business, there are many boundaries to overcome for both men and women. However, recent studies show that women specifically face more difficulties raising money through traditional fundraising channels, and the gender gap in venture capital funding is getting worse. Stories of sexual harassment and discrimination towards female founders from venture capitalists (VC’s) also abound in the news. Read More

48 Hour Film Project: Chicago Edition

WebContentFirm News


On August 25, the 48 Hour Film Project is issuing a challenge to all of Chicago’s creatives: create a short film in only 48 hours! The winning film will go on to compete “against films from around the world at Filmapalooza 2018 for a chance at the grand prize and an opportunity to screen at the Cannes Film Festival 2018 Short Film Corner,” in addition to a trophy and Movie Magic Screenwriter Software 6.Read More

New Equity Crowdfunding Rules: Expanded Options for Intrastate Fundraising

Zach ZiliakMarket Rules & Responsibilities


The Jumpstart Our Business Startups Act (JOBS Act) of 2012 created the promise of widespread crowdfunding of new business ventures.  While non-equity crowdfunding options like Kickstarter and Indiegogo had been around for years, companies could not entice investors with a share of their businesses without completing extensive disclosures, limiting their offers to accredited investors, or capping the size of their fundraising rounds to fit within various exemptions from registration as required by the Securities Act of 1933.  Now, however, businesses would be able to raise capital from a large number of investors beyond the traditional “Reg D” investors and without many of the onerous disclosures that are otherwise required of companies issuing securities, all because of these new equity crowdfunding rules. Read More

OCIE Publishes Examination Priorities for 2017

Emily HayesBest Practices, Market Rules & Responsibilities


Earlier this year, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released its Examination Priorities for 2017.  OCIE annually examines regulated entities[1] to ensure compliance, prevent fraud, identify risk, and inform policy.  These priorities reflect the practices, products, and services that, per OCIE, present the greatest risks to investors and U.S. capital markets.  Regulated entities may use the priorities to prepare for their own OCIE examinations and update their internal compliance and supervisory rules and procedures; however, the priorities do not constitute legal advice. Read More

CFTC Extends Deadline to Comply with March 1st Variation Margin Requirements

Emily HayesBest Practices, Market Rules & Responsibilities


On February 13, 2017 the Commodity Futures Trading Commission delivered an early Valentine’s Day present to swap dealers and major swap participants by extending the deadline to comply with the variation margin requirements for un-cleared swaps stipulated by Commission Regulation § 23.153 from March 1, 2017 to September 1, 2017.[1]  The CFTC’s No-Action Letter announcing this extension, CFTC Letter No. 17-11, applies only to swap dealers and major swap participants without a prudential regulator.[2]Read More

FINRA’s 2017 Regulatory and Examination Priorities

Emily HayesBest Practices, Market Rules & Responsibilities


Earlier this year, FINRA published its Annual Regulatory and Examination Priorities Letter to provide the industry with insights into the areas FINRA plans to review in its 2017 exams and to assist financial firms with reviewing and strengthening their own supervisory and compliance systems.  The letter states five priority areas the authority will focus on in its 2017 exams with a common theme of the industry’s need to focus on what FINRA President Robert Cook terms “core ‘blocking and tackling’ issues of compliance, supervision and risk management.”Read More

Amendments to CME/CBOT/NYMEX/COMEX/CME SEF Rule 432 (General Offenses) Chapter 4, Enforcement of Rules

Emmett McGrathMarket Rules & Responsibilities


Amendments to CME Rule 432 (General offenses) went into effect February 16, 2017. These amendments expand upon the protective measures previously found in CME Rule 432. The amended rule now extends liability for fraud and bad faith (432.B.1); manipulative devices, schemes, and artifices to defraud (432.H.); and delivery of false, misleading or inaccurate crop or market information (432.J.) to include mere attempts to engage in such activities.Read More

Citi Agrees to Adopt Compliance Program and Pay CFTC $25 Million for Alleged Spoofing

Emily HayesCase Studies, Market Rules & Responsibilities


Citigroup Global Markets Inc. (Citi) settled with the Commodity Futures Trading Commission (CFTC) on January 19, 2017 over the CFTC’s allegations that five traders at Citi “spoofed” the U.S. Treasury futures markets and that Citi failed to supervise the trading activity of its employees.  Pursuant to the Order, Citi must pay a fine of $25,000,000 and must maintain systems and controls that, at a minimum, detect and generate reports on trading activity that may be spoofing. Read More