On January 3, the Commodity Futures Trading Commission requested public comment on the Division of Swap Dealer and Intermediary Oversight’s Advisory regarding the applicability of transaction-level requirements to non-US swap dealers. The advisory, which was issued on November 14, stated that a non-US swap dealer entering into a swap with a non-US counterparty would nonetheless need to comply with the transaction-level requirements set forth in the CFTC’s Interpretive Guidance and Policy Statement Regarding Compliance with Certain Swap Regulations if the non-US swap dealer regularly used personnel or agents located in the United States to arrange, negotiate or execute the swap.   

Comments are due on March 10, 2014. 

The request for comment is available here.