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:

• Damian Carolan: damian.carolan@allenovery.com  / +44 203 088 2495
• John Williams: john.williams@allenover.com / +1 212 756 1131