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Further Guidance and Order with Respect to Cross-Border Application of CFTC Swap Regulation
16 January 2013
The CFTC issued a time limited exemptive order regarding the cross-border application of certain swap regulations to non-U.S. swap dealers and major swap participants, including registration requirements and certain entity-level and transaction-level requirements applicable to swaps.
The CFTC also issued further interpretation on the cross-border application of the requirement that swaps entered into by affiliates be aggregated in determining the availability of the de minimis exception from swap dealer registration.
The exemptive relief is effective until July 12, 2013, during which time the CFTC will not require the submission of a compliance plan in connection with the phasing in of compliance.
Separately, the CFTC also issued further proposed guidance on alternative definitions for the term "U.S. Person," for which the CFTC is seeking comments before February 6, 2013.
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