September 16, 2013
Allows a U.S. bank to provide counterparties with status representations to establish (i) whether a transaction is deemed to be entered into with a non-U.S. branch of such U.S. bank under the Interpretive Guidance and (ii) whether the bank satisfies requirements for a safe harbor to comply with the local law of the branch in lieu of the CFTC’s “Transaction-Level Requirements”.
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