CFTC Proposes Cross-Border Guidance and Exemptive Order
Client Newsflash

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On June 29, the CFTC released proposed interpretive guidance regarding the cross-border impact of the swap-related provisions of Title VII of the Dodd-Frank Act. The CFTC also released a proposed exemptive order that would provide non-U.S. registered swap dealers and major swap participants with temporary conditional exemptions from many swap-related Title VII requirements for one year, and permit SDs and MSPs that are U.S. persons to defer compliance with some requirements until January 2013.