On May 1st, the SEC published for comment proposed rules and interpretive guidance for parties to cross-border security-based swap transactions. The proposal explains which regulatory requirements apply when a transaction occurs partially within and partially outside the U.S. The proposed rules also set forth when security-based swap dealers, major security-based swap participants, and other entities (such as clearing agencies, execution facilities, and data repositories), must register with the SEC. The proposal outlines a "substituted compliance" framework approach which recognizes that market participants may be subject to conflicting or duplicative compliance obligations in the global derivatives market. Comments should be submitted within 90 days after publication in the Federal Register, which is expected during the week of May 6. SEC Press Release. In her open meeting remarks concerning the proposed rules, SEC Chairman Mary Jo White presented her view of substituted compliance. It "would not be based on a line-by-line comparison of the relevant rules in a foreign jurisdiction. Instead, in making a substituted compliance determination, the Commission would look at key categories of the Title VII regime, focusing on regulatory outcomes rather than the particular means of achieving those outcomes. As part of this process, the Commission would look not just at the way in which a country's laws and regulations are written, but also at how that country supervises and enforces compliance with its rules." Misgivings concerning the proposal were implied by the open meeting comments of Commissioners Luis A. Aguilar and Daniel M. Gallagher.