On July 12th, the CFTC voted to adopt an exemptive order and interpretive guidance concerning the cross-border application of its swaps regulations. The exemptive order continues the temporary conditional relief concerning the definition of U.S. person originally provided on January 13, 2013. See Exemptive Order Fact Sheet. The interpretive guidance includes a territorial based definition of "U.S. person" and provides for substituted compliance with a foreign jurisdiction's law and regulations in lieu of compliance with the requirements of the CFTC. See Interpretive Guidance Fact Sheet.