CFTC Issues Final Guidance and Accompanying Exemptive Order on Cross-Border Application of Certain Swap Regulations

Skadden, Arps, Slate, Meagher & Flom LLP

Mark D. Young Maureen A. Donley Rachel Kaplan Reicher

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.