The Commodity Futures Trading Commission adopted a final rule regarding the cross-border application of margin requirements for uncleared swaps by swap dealers and major swap participants that are not subject to requirements of prudential regulators. Under the final rule, substituted compliance with local requirements is available for initial margin posted to any non-US counterparty (including SDs and MSPs under the oversight of prudential regulators) provided the uncleared swap is not guaranteed by a US person. Substituted compliance will not apply to initial margin collected from a non-US counterparty. Commissioner J. Christopher Giancarlo dissented from the final margin rule claiming that its “preconditions to substituted compliance … is overly complex, unduly narrow and operational impractical.”