With Dickson Chin, Jonathan Ching, Ilene Froom, James Gauch, Tracy Oley, Jay Tambe, Joel Telpner, Alice Yurke
On November 14, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission created confusion and consternation in the derivatives world by issuing an advisory indicating that certain requirements will apply to swaps entered into between a registered non-U.S. swap dealer and a non-U.S. person if the swap is handled by personnel or agents of the non-U.S. swap dealer located in the United States.