February 24, 2016
Stroock Special Bulletin
On February 10, 2016, the Securities and Exchange Commission ("SEC") released its final rule governing the cross-border application of the de minimis exception from designation as a security-based swap dealer. Under the final rule, a non-U.S. person will be required to include, in its calculations of whether it qualifies for such de minimis exception, security-based swaps that are arranged, negotiated or executed by personnel (or personnel of an agent) located in a U.S. branch or office.
This Stroock Special Bulletin focuses on the SEC's test for such arrangement, negotiation or execution.
February 24, 2016
Stroock Special Bulletin
On February 10, 2016, the Securities and Exchange Commission ("SEC") released its final rule governing the cross-border application of the de minimis exception from designation as a security-based swap dealer. Under the final rule, a non-U.S. person will be required to include, in its calculations of whether it qualifies for such de minimis exception, security-based swaps that are arranged, negotiated or executed by personnel (or personnel of an agent) located in a U.S. branch or office.
This Stroock Special Bulletin focuses on the SEC's test for such arrangement, negotiation or execution.
