CFTC Proposes Rules to Count Cross-Border Swaps for Swap-Dealer Thresholds and Other Requirements

Skadden, Arps, Slate, Meagher & Flom LLP

Mark D. Young Maureen A. Donley Daniel B. O'Connell Shekida A. Smith

The CFTC’s newly proposed rules on cross-border transactions address which swap activities affect swap-dealer thresholds and trigger transaction-level swap requirements. These are the latest in a series of CFTC rulemakings, orders and guidance on cross-border issues arising from the Dodd-Frank Act.

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