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Swap Dealers Cross-Border Transactions Reporting Requirements

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
McDermott Will & Schulte

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

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

Orrick, Herrington & Sutcliffe LLP

SEC Amends Rules on Security-Based Swap Reporting

On July 13, 2016, the Securities Exchange Commission (“SEC”) approved certain amendments and guidance to the rules governing the reporting and public dissemination of security-based swaps (“SBS”), known as “Regulation SBSR,”...more

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