On July 23, 2020, the Commodity Futures Trading Commission (the “CFTC” or the “Commission”) held an open meeting at which it voted 3-2 (with Commissioners Behnam and Berkovitz dissenting) to adopt a final rule regarding the cross-border application of the registration thresholds and certain requirements applicable to swap dealers and major swap participants in connection with cross-border transactions (the “Final Rule”). The Final Rule came into effect on November 13, 2020, and compliance will be required in September 2021. The Final Rule largely follows the rule proposed by the Commission on December 18, 2019 (the “Proposed Rule”), and replaces existing interpretive guidance released by the Commission in 2013 and the never-finalized cross-border swap rules the Commission proposed in October 2016.