Non-US Person Swap Trading Gets Pass
By John Hintze, iTreasurer
October 18, 2016

Christopher Bender, a director of regulatory advisory on Chatham Financial’s Global Regulatory Solutions team, said “A benefit to the proposal is that if you are a non-US person corporate and you’re trading with a non-US swap dealer, then the proposed rule confirms that the corporate is exempted from having to comply with the external business conduct standards unless the transaction is negotiated or executed in the United States, but if the transaction is arranged, negotiated or executed (ANE) in the US, then certain external business conduct requirements would still apply.”

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