CFTC Staff Issues Advisory On The Applicability Of Transaction-Level Requirements In Certain Cross-Border Situations

Today, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) responded to an inquiry from swap market participants and other interested parties on the applicability of Dodd-Frank Transaction-Level Requirements to swaps between non-U.S. swap dealers (SDs) (whether an affiliate or not of a U.S. person) and non-U.S. persons if the swap is arranged, negotiated, or executed by personnel or agents of the non-U.S. SD located in the U.S. DSIO is issuing a Staff Advisory to help market participants better understand the applicability of the Commission’s rules.