CFTC substituted compliance process not clear enough – Risk.net poll
The majority of respondents to a Risk.net poll say they do not understand how CFTC substituted compliance determinations will be made
Nearly three-quarters of respondents to a Risk.net poll say they do not understand how substituted compliance will work under Commodity Futures Trading Commission (CFTC) rules – creating huge uncertainty ahead of the end of an exemptive order, which is due to expire on December 21.
Substituted compliance is the centrepiece of the CFTC's interpretative guidance on the cross-border application of the Dodd-Frank Act, finalised on July 12. Essentially, it allows non-US swap dealers, non-US major
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