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Legal Update

Proposed CFTC Guidance Regarding the Cross-Border Application of US Swap Regulations

2 July 2012
Mayer Brown Legal Update
The US Commodity Futures Trading Commission has 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 Wall Street Reform and Consumer Protection Act. The Proposed Guidance addresses both (i) when non-US persons must register as a swap dealer or major swap participant (“MSP”), and (ii) the extent to which a non-US person will be subject to the substantive regulatory requirements applicable to registered swap dealers and MSPs. Comments on the Proposed Guidance are due 45 days after publication in the Federal Register. This Legal Update identifies and summarizes key aspects of the Proposed Guidance.


  • Joshua Cohn
    Senior Counsel, Independent Contractor
    T +1 212 506 2539
  • Curtis A. Doty
    T +1 212 506 2224
  • Jerome J. Roche
    T +1 202 263 3773
  • David R. Sahr
    T +44 20 3130 3496
  • Donald S. Waack
    T +1 202 263 3165

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