In his second article, Keyser Sose, our anonymous Sef operator, vents his frustration at the conflicting and confusing regulatory framework.
it’s been an interesting month in Sef World. A
plethora of confusion was then supplanted by a plethora of
Guidance and No Action letters that left, well, more confusion.
when is a non-US Person a US Person. Prior to November 14 there
was a widely held view that the entities caught by DFA were
only those who were actually US entities. By that I mean US
institutions and any overseas branch offices they may
being is that their failure could potentially be paid for by
the US taxpayer. Anyone else, even if they were actually based
in the US was not a US Person and on the basis of many, but not
all interpretations, was not subject to CFTC Transaction Level
Requirements, including the requirement to trade on a
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