When a Commodity Futures Trading Commission exemptive order expires in July, many non-U.S. companies may be redefined as a "U.S. person" and thus need to comply with the Dodd-Frank Act's clearing regulations. "It is a real problem not knowing whether your counterparty is a U.S. person or not," said Scott Cammarn of Cadwalader, Wickersham & Taft. "Maybe they are not today, but then when the exemptive order runs out on July 12 and the definition changes, all of a sudden they are a U.S. person." Register now for SIFMA's Putting the Clear in Central Clearing Conference.
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