Biography
Andrew P. Cross is a seasoned derivatives and investment management attorney who represents financial institutions, commodity trading firms, family offices, public companies and other corporate end-users, registered investment advisers, registered investment companies, and private funds.
Andrew routinely negotiates complex derivatives transactions and related trade agreements, so that clients can achieve their investment and risk management objectives. His practice focuses on the representation of buy-side clients with particular attention given to issues faced by registered investment advisers and their institutional clients.
On the regulatory front, Andrew’s practice covers issues arising under federal statutes that govern the use of derivatives for investment or hedging purposes. He routinely advises clients regarding the application of the Commodity Exchange Act, the Securities Act, the Securities Exchange Act, the Investment Company Act, and the Investment Advisers Act.
Additionally, Andrew has more than 20 years of experience as an investment management attorney, regularly advising mutual funds and their boards and investment advisers with respect to regulatory matters, client commission arrangements and related fiduciary oversight matters, as well as fintech regulatory issues.
Experience
- Negotiate master trading agreements, including ISDA Master Agreements and Credit Support Annexes (“CSAs”), Master Securities Forward Transaction Agreements (“MSFTAs”), Master Repurchase Agreements (Repos), Futures and Options Account Agreements, and Cleared Derivatives Addenda and Cleared Derivatives Execution Agreements (“CDEAs”).
- Negotiate account control agreements and other margin arrangements related to derivatives transactions.
- Negotiate share repurchase and call spread transactions on behalf of public companies.
- Advise on structuring of interest rate, foreign exchange, credit, equity, and energy derivatives.
- Prepare derivatives and risk management compliance policies and procedures for investment advisers and funds, banks, and public company clients.
- Counsel commodity pool operators and commodity trading advisors with respect to Commodity Futures Trading Commission (“CFTC”) regulatory and compliance considerations.
News & Views
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Event
Tenth Annual Energy Industry Update: Innovating | Adapting | Advancing
Blank Rome-Hosted EventSusan L. Bickley, Andrew P. Cross, Ryan A. Haddad, Margaret Anne Hill, Matthew D. Lea, Keith B. Letourneau
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Blog Post
CFTC’s GMAC: Bank Capital Proposals Will Harm Cleared Derivatives Markets and Improvements Needed to Variation Margin Processes in Non-Cleared Markets
The BR Derivatives Report -
Press Release
Blank Rome Awards Inaugural Energy Scholarship to University of Houston Law Student
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Event
8th Annual North American Environment, Energy & Natural Resources Conference
University of Houston Law CenterSusan L. Bickley, Keith B. Letourneau, Michael I. Sanders, Andrew P. Cross
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Blog Post
Part 12: Amendments to Other CFTC Regulations to Account for Proposed Regulation §1.44
The BR Derivatives Report -
Blog Post
Part 11: Information and Disclosure Requirements in the Separate Account Context
The BR Derivatives Report -
Blog Post
Part 10: Capital, Risk Management, and Segregation Calculations by FCMs
The BR Derivatives Report -
Blog Post
Part 9: The One Business Day Margin Call Requirement—Miscellaneous Considerations
The BR Derivatives Report -
Blog Post
Part 8: The One Business Day Margin Call Requirement under CFTC Regulation §1.44
The BR Derivatives Report -
Blog Post
Part 7: The Ordinary Course of Business and the Separate Account Election
The BR Derivatives Report
Credentials
Admissions
- Pennsylvania
- District of Columbia
Education
- University of Balamand, MA
- Washington & Jefferson College, BA, summa cum laude
- University of Pittsburgh School of Law and Katz School of Business, JD/MBA