The rule proposal we have before us is significant. It addresses a number of important issues including: (i) the “US Person” definition; (ii) the treatment of foreign affiliates of US Persons (“Foreign Consolidated Subsidiaries” or “FCS”); (iii) the application of the de minimis threshold and business conduct standards to non-US registered dealers; and (iv) the treatment of swap trades that are “arranged, negotiated, or executed” in the US by foreign-based dealers but booked elsewhere.
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