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Fact Sheet

Fact Sheet: Elements of the CFTC's Proposed Cross-Border Regulations Facilitate Regulatory Arbitrage, If Not Evasion, of U.S. Law

On March 9, 2020, Better Markets filed a comment letter on the Commodity Futures Trading Commission’s (“CFTC”) proposed framework for applying the Dodd-Frank Act’s swaps requirements to certain non-U.S. activities and non-U.S. persons having a direct and significant (1) connection with activities in U.S. commerce; or (2) effect on U.S. commerce.

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