News & Analysis as of August 11, 2025

Swap Dealers

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A repository for the most well-read content on JD Supra at any given time, along with occasional roundups of popular content by specific topic. Also stop by for monthly recaps of hot articles for the previous... more +

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

McDermott Will & Schulte on 6/9/2025

On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Key Differences Between CFTC and SEC Final Business Conduct Standards and Related Cross-Border Requirements

WilmerHale on 9/26/2016

The Securities and Exchange Commission (SEC) recently adopted final business conduct rules for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) under Section 15F(h) of the Securities...more

SEC Proposes Rules to Oversee Non-US Firms’ Swap Activity in the United States

WilmerHale on 5/3/2015

On April 29, 2015, the US Securities and Exchange Commission (SEC) proposed new rules to enhance its oversight of non-US firms’ security-based swap activity in the United States. The proposal, if adopted, will have important...more

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CFTC Staff Letter 25-14: What Is a “U.S. Person”?

Key Differences Between CFTC and SEC Final Business Conduct Standards and Related Cross-Border Requirements

SEC Proposes Rules to Oversee Non-US Firms’ Swap Activity in the United States

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