On May 24, 2016, the Commodity Futures Trading Commission (CFTC) adopted final rules (cross-border margin rules) that specify how its recently issued uncleared margin rules apply to cross-border transactions. Chairman Timothy Massad and Commissioner Sharon Bowen voted in favor of the rules. Commissioner J. Christopher Giancarlo voted against the rules, protesting what he views to be an overly complicated approach: “In effect, the Commission’s approach is somewhat principles-based, except when it is rulesbased and somewhat objective, except when it is subjective.” The rules go into effect 60 days from the date of publication in the Federal Register.