Time to end clash over Dodd-Frank extraterritoriality

Nick Sawyer

A recent Dodd-Frank rule-making proposal from five US prudential regulators has caused a bit of a stir. People have been worried for some time about the territorial scope of the Dodd-Frank Act, and whether global banks might find themselves subject to multiple sets of rules or whether US banks might be put at a competitive disadvantage in overseas markets. The April 12 proposal on margin requirements for non-cleared swaps confirmed their worst fears.

The proposal essentially captures non-US swap