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4/21/16 - Non-US Swap Dealers Face New Registration Requirements

The number of non-U.S. companies registering as security-based swap dealers with the Securities and Exchange Commission is likely to increase due to regulations approved earlier this year that require these companies to count any security-based swap transacted by U.S.-based personnel toward the SEC’s registration threshold. Firms that exceed those thresholds have until Feb. 21, 2017, to apply to the SEC for registration — a process in which senior officers of applicants certify that their firms have policies and procedures for compliance with U.S. securities laws. Non-U.S. firms that must register will then be subject to SEC supervision of their business operations and new reporting requirements.

Please click “Read More” below to read a Sightlines InFocus by Douglas Harris and Peter Curley, “Non-U.S. Swap Dealers Face New Registration Requirements,” which helps companies determine whether they fall within the rulemaking’s scope and will face these new compliance challenges.