The CFTC has proposed rules that would define the reach of Dodd-Frank Act margin requirements in cross-border swap transactions.

On June 29, 2015, the US Commodity Futures Trading Commission (CFTC) proposed regulations that would frame the reach of its uncleared swap margin requirements in cross-border swap transactions (the Proposed Rules). The Proposed Rules follow the margin rules the CFTC reproposed last year, which outlined three different approaches for purposes of applying the margin rules in a cross-border context. The Proposed Rules do not reflect one of the three approaches originally proposed in 2014, but rather take a different (hybrid of sorts) approach to the cross-border application of the CFTC uncleared swap margin rules.