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Swap Dealers Today's Popular Updates Cross-Border Transactions

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

WilmerHale

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

WilmerHale on

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

WilmerHale

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

WilmerHale on

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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