SEC Takes Critical Step Toward Completing Dodd-Frank’s SBS Regime

On May 10, 2019, the Securities and Exchange Commission proposed supplemental guidance and rule amendments addressing the cross-border application of certain rules regulating security-based swaps pursuant to Title VII of the Dodd-Frank Act.

The proposal is a critical step towards completing the SEC’s implementation of the Dodd-Frank Act’s SBS regime and raises a number of key questions for market participants to consider.  This memorandum provides a summary of the proposal.  Comments on the proposal are due 60 days after its forthcoming publication in the Federal Register.