What’s on International Treasurer’s radar screen this week.
This week’s editorial meeting brought forth several topics that International Treasurer will investigate in the coming weeks. First up is the latest CFTC timeline for the remaining rules and compliance deadlines. Also, we’ll take a look at companies can prove their end-user status. Finally, companies are getting more granular when it comes to cash, particularly overseas or trapped cash, the latter of which has been requested by the Security & Exchange Commission.
CFTC timeline. Earlier this month, the CFTC gave a first glimpse at the timeline for the remaining rules and compliance deadlines for certain new regulatory requirements. In recently proposed rules, the CFTC set forth a schedule for a phased implementation of the clearing, trading and margin requirements. The article looks at these items as well as key rules that have an impact on corporate treasurers, such as the end-user exception from mandatory clearing and the reporting requirement.
End-user? Prove it. One of the many misconceptions companies hold surrounding coming Dodd-Frank Act rules regards their end user exemption. Companies are not automatically exempt and must go through a process. We’ll also explore some of the methods allowed to prove you are hedging your commercial risk and not trading; also a look at rules in what defines an MSP (major swap participants), whether a hedge is reasonably effective or not defined qualitatively (vs. quantitatively – under the FAS 133 ED that would change).
What’s in the cash bucket. As corporate cash piles continue to grow, so is the scrutiny of that cash, where it is, what it is and how it will be reported. Recently the SEC asked companies to provide investors with more information about cash they hold offshore. More rigor around reporting what’s in the cash bucket was also a discussion at the NeuGroup’s recent Engineering & Construction Treasurers’ Peer Group.