The CFTC recently adopted final guidance on how Dodd-Frank requirements will apply to cross-border swap activities and issued an order on the phased-in implementation of the new rules. CFTC Commissioner Bart Chilton calls the guidance the agency's most complicated undertaking in the past three years.
CFTC Issues Final Guidance and Accompanying Exemptive Order on Cross-Border Application of Certain Swap Regulations
Skadden, Arps, Slate, Meagher & Flom LLP