The Commodity Futures Trading Commission (CFTC) on Monday issued an order simultaneously filing and settling charges against Goldman Sachs & Co. LLC for violations of the CFTC’s Business Conduct Standards applicable to swap dealers.
Specifically, the CFTC found that Goldman failed to disclose dozens of pre-trade-mid-market marks (PTMMM), in violation of Regulation 23.431, and failed to communicate to clients in a fair and balanced manner based on principles of fair dealing and good faith, in violation of Regulation 23.433.
Goldman admits that for nearly all “same-day” swaps executed in 2015 and 2016, it either failed to disclose any PTMMM or failed to disclose an accurate PTMMM, and that this conduct violated a CFTC regulation.
The order imposes a $15,000,000 civil monetary penalty.
The…
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