ISDA and Markit launched the ISDA Cross-Border Swap Representation Letter on ISDA Amend. The Cross-Border Letter allows market participants to provide counterparties with representations for U.S. persons status to determine whether compliance with various swap regulations is required by the CFTC’s Interpretive Guidance. ISDA and Markit made the representations found in the Cross-Border Swaps Representation Letter available via ISDA Amend. The substantive representations on ISDA Amend are identical to ISDA’s letter.
See: ISDA Press Release.
Related News: CFTC Posts “Cross-Border Guidance” and “Cross-Border Exemptive Order” (July 16, 2013); CFTC Approves Cross-Border Guidance and Exemptive Order (July 15, 2013).