SEC Proposes Rules for Cross-Border Security-Based Swap Transactions

On April 29, the Securities and Exchange Commission published proposed rules that would require non-United States persons that use United States personnel to arrange, negotiate or execute a security-based swap transaction in connection with its dealing activity to include such transaction for purposes of the de minimis exception set forth in Exchange Act Section 3(a)(71)(D).  Comments to the proposed rule are due 60 days after publication in the Federal Register.  ReleaseProposed Rule.