On June 29, 2012, the US Commodity Futures Trading Commission (the "CFTC") released its proposed interpretive guidance and policy statement (the "Proposed Guidance") regarding the cross-border application of the swaps provisions of Title VII of the Dodd-Frank Act. In addition, the CFTC released a proposed exemptive order that would provide non-US swap market participants with conditional temporary relief from certain Title VII requirements for one year.
Please join Mayer Brown attorneys Josh Cohn, David Sahr and Donald Waack in a discussion of the following topics:
- The CFTC's proposed interpretation of the cross-border reach of Title VII's swap provisions and the potentially significant impact of the proposal on US and non-US swap markets;
- The effect of the proposed exemptive order, clarification of relevant definitions and what this means for market participants; and
- The CFTC's phased implementation schedule and remaining uncertainties for non-US swap market participants.
Mayer Brown's Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm's global resources from multiple practices and offices, the Initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.