In May 2013, the U.S. Securities Exchange Commission (SEC) issued the consultative proposal "Rules for Cross-Border Security-Based Swap Activities", explaining which regulatory requirements apply when a transaction occurs partially within and partially outside the U.S. The proposed rules also set forth security-based swap dealers, major swap participants, and other entities which are eligible for SEC registration. In addition, the proposal outlines "substituted compliance" framework which allows foreign financial institutions comply with foreign laws and regulations in substitution for complying SEC rules.

JSDA Letter to SEC