Debevoise & Plimpton

CFTC no-action relief and request for comment for the transaction-level requirements of non-US swap dealers

On 14 November 2013, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) issued Advisory 13-69 in response to inquiries from swap market participants as to whether a non-US swap dealer (SD) must comply with the transaction-level requirements set forth in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the CFTC’s regulations thereunder when entering into a swap with a non-US person if the swap is arranged, negotiated or executed by personnel or agents of the non-US SD located in the US.

Subsequent to the issuance of the advisory, certain non-US SDs raised concerns regarding compliance with the transaction-level requirements for swaps with non-US persons that are not guaranteed affiliates or conduit affiliates of a US person where the non-US SD uses personnel or agents located in the US to arrange, negotiate or execute such swaps…

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