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CFTC Announces Two Cross-Border Related Actions

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The U.S. Commodity Futures Trading Commission (CFTC) today announced two separate actions on how the rules related to the Dodd-Frank Wall Street Reform and Consumer Protection Act apply to cross-border transactions. Specifically, the CFTC issued a Final Response to District Court Remand Order in Securities Industry and Financial Markets Association, et al. v. United States Commodity Futures Trading Commission. Also today, the CFTC’s Divisions of Swap Dealer and Intermediary Oversight (DSIO), Clearing and Risk, and Market Oversight (Divisions) issued a time-limited no-action letter that extends relief, which was originally provided in November 2013 and subsequently extended, to swap dealers registered with the CFTC that are established under the laws of jurisdictions other than the United States from certain transaction-level requirements under the Commodity Exchange Act.

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