CFTC Chairman Gensler Previews Key Elements of Dodd-Frank Title VII Cross-Border Guidance
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In a speech today at the 2012 FINRA Annual Conference, CFTC Chairman Gary Gensler provided a preview of the CFTC's much anticipated guidance regarding cross-border application of Title VII of the Dodd-Frank Act. According to Chairman Gensler, the proposed cross-border guidance, which is expected sometime in June, will address how Title VII's registration, transaction-level and entity-level requirements for swap dealers and major swap participants (collectively, "Swaps Entities") would apply to non-U.S. Swaps Entities, including those non-U.S. Swaps Entities that are affiliated with U.S. financial institutions. Chairman Gensler's five-point summary of the key elements of the forthcoming guidance is provided below, followed by our views of potential implications and open issues associated with each key element.