Ian Cuillerier

Ian Cuillerier

White & Case LLP

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Foreign Banking Organizations Granted Benefit of Swaps Push-Out Rule and Transition Period

The Board of Governors of the Federal Reserve System ("Board") on December 24, 2013, issued final rules ("Final Rules") to include the uninsured US branches and agencies of foreign banks in the definition of "insured...more

1/3/2014 - Dodd-Frank FDIC Foreign Banks Push-Out Requirements Section 716 Swaps

Final Exemptive Order Regarding Cross-Border Application of Certain Swap Regulations

On July 13, 2013, the Commodity Futures Trading Commission (the “CFTC”) approved a second final exemptive order (the “Final Order”) providing time-limited relief from certain cross-border applications of the swaps provisions...more

8/23/2013 - CFTC Dodd-Frank Major Swap Participants Swap Dealers Swaps Title VII

CFTC Approves Final Interpretative Guidance With Respect To The Cross-Border Application Of Certain Swap Provisions Of The...

Introduction - On July 12, 2013, the Commodity Futures Trading Commission (the “CFTC” or the “Commission”) approved final interpretative guidance (the “Final Guidance”)1 regarding the cross-border application of...more

8/22/2013 - CFTC Commodities Exchange Act Compliance Cross-Border Major Swap Participants Swap Dealers Swaps

Foreign Banks May Continue Swaps Activities...and Still Access Discount Window

The Board of Governors of the Federal Reserve System (“Board”) on June 5, 2013 took a bold step in issuing interim final rules (“Interim Rules”) that allow a foreign bank’s uninsured US branches and agencies to continue to...more

6/14/2013 - Discounts Federal Reserve Foreign Banks Swap Dealers Swaps

CFTC Approves Final Regulations Governing Clearing Exemption for Swaps Between Certain Affiliated Entities and Provides No-Action...

On April 1, 2013, the Commodity Futures Trading Commission (“CFTC”) approved a final rule (Regulation 50.52) exempting swaps between certain affiliated entities from the clearing requirements of the Commodity Exchange Act...more

6/3/2013 - CEA CFTC Derivatives Clearing Organizations Dodd-Frank GAAP IFRS Mandatory Clearing Requirements No-Action Letters Reporting Requirements Swaps

SEC Proposed Rules on Cross-Border Security-Based Swap Activities

Introduction - On May 1, 2013, the Securities and Exchange Commission (“SEC”) adopted and made public for comment proposed rules and interpretive guidance (“Proposed Rules”) to address the application of the provisions...more

6/3/2013 - Cross-Border Dodd-Frank Foreign Branches of U.S. Banks Major Swap Participants Registration SEC Securities Exchange Act Security-Based Swaps SEFs Swap Dealers Swaps Title VII

Deferral of the Swaps Push-Out Requirement, But Only for Insured Federal Depository Institutions

An insured federal depository institution may request a transition period to comply with the “push-out” requirements of section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”)...more

1/17/2013 - Compliance Dodd-Frank FDIC Federal Reserve OCC Push-Out Requirements Swap Dealers Swaps

The CFTC Issues Interim Final Rules Extending the Time for Compliance with Certain Business Conduct and Documentation Requirements...

On December 18, 2012, the US Commodity Futures Trading Commission’s (the “Commission”) approved interim final rules (the “Interim Final Rules”) for swap dealers (“SDs”) and major swap participants (“MSPs”) that delay...more

1/11/2013 - CFTC Dodd-Frank Major Swap Participants Required Documentation Swap Dealers Swaps

Final Exemptive Order Regarding Compliance With Certain Swap Regulations; Further Proposed Guidance

On December 21, 2012, the Commodity Futures Trading Commission (the “Commission” or “CFTC”) approved an exemptive final order (the “Final Order”) providing time-limited relief from certain cross-border applications of the...more

1/3/2013 - CEA CFTC Cross-Border Transactions Dodd-Frank Swaps

The CFTC Issues Interim Final Rules Extending the Time for Compliance for Certain Business Conduct and Documentation Requirements...

On December 18, 2012, the US Commodity Futures Trading Commission’s (the “Commission”) approved interim final rules (the “Interim Final Rules”) for swap dealers (“SDs”) and major swap participants (“MSPs”) that delay...more

12/29/2012 - Business Conduct Standards CFTC Compliance Dodd-Frank ISDA Major Swap Participants Required Documentation Swap Dealers Swaps

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