On January 16, 2014, Clifford Chance released a briefing, available here, on exemptions for inter-affiliate and intragroup transactions under the U.S. Dodd-Frank Act and the European Market Infrastructure Regulation (“EMIR”). Both impose obligations requiring the clearing and reporting of certain derivative transactions and the margining of uncleared trades. However, there are differences as to how the U.S. and the EU regimes apply to inter-affiliate or intragroup transactions.
Our briefing summarizes and compares the relevant U.S. Commodity Futures Trading Commission (“CFTC”) rules against the relevant E.U. rules. It is not intended to be comprehensive or to provide legal advice.
The full briefing is available here.