• Update: An End-User’s Guide to the CFTC’s Final Cross-Border Guidance
  • January 24, 2014
  • Law Firm: Sutherland Asbill Brennan LLP - Washington Office
  • There were a number of new developments with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requirements for swaps in the latter part of 2013. This Legal Alert summarizes the developments and should be considered an update of our August 2013 Legal Alert titled An End-User’s Guide to the CFTC’s Final Cross-Border Guidance (the “August Cross-Border Legal Alert”), which focused on the U.S. Commodity Futures Trading Commission’s (“CFTC”) final interpretive guidance concerning the cross-border application of the Dodd-Frank Act (the “Interpretive Guidance”) from an end-user’s perspective. For the purpose of this Legal Alert, we use the term “end-user” to refer to any entity that is not registered as a swap dealer or major swap participant with the CFTC.