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Better Markets Comment Letter on Cross-Border Application of the Registration Thresholds and Certain Requirements Applicable to Swap Dealers and Major Swap Participants

On March 9, 2020, Better Markets filed a comment on the Commodity Futures Trading Commission’s proposed rulemaking codifying and amending elements of its 2013 cross-border guidance.  The proposal, in essence, sets forth a regulatory framework for the application of U.S. law to non-U.S. activities and non-U.S. legal entities posing direct and significant risks to the U.S.