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Jul 17, 2012

Cross-Border Application of the Swaps Provisions of the Dodd-Frank Act

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The CFTC has proposed long‑awaited interpretive guidance concerning the extent to which the new registration and regulatory requirements for swaps under the Dodd‑Frank Act apply to transactions and persons outside of the United States. Since the Dodd-Frank Act was introduced, its perceived extraterritoriality has been one of the major talking points and controversies. The interpretive guidance, if adopted, would address certain key concerns raised by market participants since the enactment of the Dodd‑Frank Act, particularly in the context of swap dealer and major swap participant registration.

View full memo, "Cross-Border Application of the Swaps Provisions of the Dodd-Frank Act"

Authors and Contributors

Donna Parisi

Partner

Derivatives & Structured Products

+1 212 848 7367

+1 212 848 7367

New York

Azam Aziz

Partner

Derivatives & Structured Products

+1 212 848 8154

+1 212 848 8154

New York

Geoffrey Goldman

Partner

Derivatives & Structured Products

+1 212 848 4867

+1 212 848 4867

New York

Bradley K. Sabel

Of Counsel

Financial Institutions Advisory & Financial Regulatory

+1 212 848 8410

+1 212 848 8410

New York

Russell Sacks

Partner

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7585

+1 212 848 7585

New York

Barnabas Reynolds

Partner

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5528

+44 20 7655 5528

London

Patrick Clancy

Partner

Finance

+44 20 7655 5878

+44 20 7655 5878

London

Thomas Donegan

Partner

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5566

+44 20 7655 5566

London