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External Meetings: Telephone Call with Ed Rosen
Ed Rosen (Cleary, Gottlieb, Steen & Hamilton)
Cleary, Gottlieb, Steen & Hamilton
The participants discussed issues in the cross-border guidance. In particular they discussed the major swap participant threshold as applied to non-U.S. persons, the definition of “foreign branch” of a U.S. person, and the application of the swap dealer registration requirement to non-U.S. persons that are guaranteed by U.S. persons.