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Update on the CFTC’s Cross-Border Application of Dodd-Frank Swaps Requirements
Lihua Chen,Katherine Dobson,Joshua B. Sterling, January 3, 2014
On December 20, 2013, the CFTC issued further guidance addressing the cross-border application of its swaps rules under Dodd-Frank. The guidance took the form of “substituted compliance” determinations and no-action relief for swap dealers (and major swap participants) located in...
Update on Mandatory On-Facility Trading of Swaps
Akshay N. Belani,Lihua Chen,Joshua B. Sterling, December 12, 2013
Under the Commodity Exchange Act, as amended by Dodd-Frank, certain swaps must be cleared as determined by the CFTC. In late 2012, the CFTC determined that major classes of interest swaps and index credit default swaps would become subject to this mandatory clearing requirement. That clearing...