Scott O'Malia, a member of the Commodity Futures Trading Commission, says the agency has yet to begin working on the final definition of "U.S. person," which affects the cross-border application of several of its Dodd-Frank Act rule makings. "I have no idea how that's going to be worked out at this point. I believe we will need to provide relief and the debate will be about whether to continue to extend the relief as is -- with maybe some changes to the U.S. person definition -- or to implement the entire cross-border guidance and then provide exemptive relief to certain elements of that," O'Malia says.

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