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October 30, 2012

What does the US CFTC’s Cross-Border Guidance mean for the European Swaps Market: A&O

Allen & Overy delivered another in their series of lunchtime seminars on the cross border / extra-territorial issues in Europe from the implementation of the Dodd Frank Act via the CFTC. A&O provided this PDF which includes:

  • Status of the CFTC rule making
  • Key dates
  • The registration requirements
  • Swaps proposed for mandatory clearing
  • Clearing exemptions
  • Phase-in timeline
  • Who is a Swap Dealer? MSP? US Person?
  • Branches and Affiliates
  • Aggregation rules
  • Substituted compliance
  • Role of a Chief Compliance Officer and how this differs outside the US

Without the commentary and expert insights from A&O this material hints at issues, you should contact A&O to get more details:

 


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