On October 11, 2016, the Commodity Futures Trading Commission (the “CFTC”) proposed new rules (the “Proposed Rules”) addressing the cross-border application of the registration thresholds and external business conduct standards (“EBCS”) for swap dealers (“SDs”) and major swap participants (“MSPs”), including the extent to which the Proposed Rules would apply to swap transactions that are arranged, negotiated, or executed using personnel located in the United States (“ANE Transactions”). 81 Fed. Reg. 71946 (October 18, 2016). If adopted, the Proposed Rules would supersede the CFTC’s 2013 Interpretive Guidance and Policy Statement Regarding Compliance with Certain Swap Regulations (the “Guidance”) in a number of significant respects. Comments on the Proposed Rules must be received on or before December 19, 2016.