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