Crossed wires

duncan-wood

Confusing, inconsistent, troubling, schizophrenic, messy – some of the adjectives lawyers are using to describe guidance published by the US Commodity Futures Trading Commission (CFTC) on the cross-border application of its Dodd-Frank Act rules. It’s a crucial document, which lays out the scope of the US regulations – whether foreign branches of US banks have to register as swap dealers, for example, and whether wholly foreign entities that trade with US institutions have to comply with transact