CFTC Clarification Of Footnote 513 Extends DF Reach

The U.S. Commodity Futures Trading Commission has substantially expanded the scope of its cross-border reach with a document specifying that employees from non-U.S. firms based in the U.S. must comply with Dodd Frank, even if they are processing non-U.S. swaps, according to lawyers. Until now, the issue was specified in footnote 513 of cross-border guidance released by the CFTC in July, which referred to foreign branches but not affiliates, or agents, in the U.S.