Extraterritorial derivatives guidance proposed by CFTC: More analysis required, impact unclear

July 2012


On June 29, 2012, the CFTC released its much anticipated proposed cross-border guidance to interpret when Dodd-Frank Act derivatives regulations reach beyond US shores. It also released a proposed exemptive order that would grant temporary relief from compliance dates for certain regulations.

Because ultimately each firm needs to do its own firm-specific analysis, this FS Regulatory Brief offers general observations for US and foreign swap dealers to consider. It also provides a table for assessing the projected regulatory impact on the particular entity or office engaged in swap activities.

To read this FS Regulatory Brief, please click here.

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Dan Ryan
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Alison Gilmore
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Tel: +1 (646) 471 0588