Goldman Sachs Fined $15 Million for Swap Business Violations

The Commodity Futures Trading Commission (CFTC) has ordered Goldman Sachs to pay a $15m civil monetary penalty for violating the CFTC's Business Conduct Standards applicable to swap dealers. The CFTC found that Goldman failed to disclose dozens of pre-trade-mid-market marks (PTMMM) and failed to communicate to clients in a fair and balanced manner based on principles of fair dealing and good faith. 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.