The division of swap dealer and intermediary oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) has issued an advisory on the applicability of transaction-level requirements in certain cross-border situations.

The DSIO was responding to an inquiry from swap market participants and other interested parties on the applicability of Dodd-Frank Transaction-Level Requirements to swaps between non-US swap dealers (SDs) (whether an affiliate or not of a US person) and non-US persons if the swap is arranged, negotiated, or executed by personnel or agents of the non-US SD located in the US. 
 
DSIO is issuing a staff advisory to help market participants better understand the applicability of the commission’s rules.