The CFTC issued an amended no-action letter addressing the pay-to-play rules applicable to swap dealers who conduct business with certain governmental special entities. The original CFTC Letter (12-33) was issued on November 20, 2012. The pay-to-play rules in CFTC Rule 23.451 ("Political contributions by certain swap dealers") restrict a swap dealer from engaging in certain activities with a governmental special entity, if the swap dealer (or a covered associate of the swap dealer) made or solicited contributions to an official of that governmental special entity during the preceding two years

In a statement at the CFTC's 2012 Research Conference, Commissioner Chilton suggests that there is "mounting evidence that speculation affects commodity prices". Citing a number of studies in favor of this claim, Commissioner Chilton states that the next position limits proposal from the CFTC will focus more on speculation studies. Citing to the song by Everclear, Commissioner Chilton says that Wall Street must " Be Careful What You Ask For." (Warning: not something I would ever listen to, other than in the context of doing my day job.) Lofchie Comment: I think it is a really great thing that

The Division of Corporation Finance provided no-action relief to Minnesota Soybean Processors, an agricultural co-operative, that its conversion from one form of co-operative to another was not subject to the Securities Act of 1933. The relief was based on the fact that the various interests issued by the entity were not "securities" for purposes of the Securities Act, and thus the transfer of such interests could not constitute a sale of "securities". Cross-Reference(s): Exchange Act Section 2(a)(1). Lofchie Comment: For lawyers seeking to re-create their youth, reading the incoming letter is

The Division of Corporation Finance is providing no-action relief to Chai-Na-Ta Corp. As the entity is in liquidating mode, the Division will not object if Chai-Na-Ta does not file future periodic reports under Exchange Act Section 13(a), subject to the various conditions set forth in the letter. View letter in full here (links externally to SEC website). See also: Incoming Letter

Click on the links below to learn more about each insider trading case: Brazilian Ex-Banker to Pay $5.1 Million for Insider Trading in Burger King Stock Connecticut-Based Business Executive Charged with Insider Trading During Bidding Process China North East Petroleum Holdings Limited, et al.