enacted in the wake of financial crisis. have certain provisions that have extraterritorial implications on foreign jurisdictions as they impose registration/recognition, reporting requirements, etc. with potential to increase complexity, introduce uncertainty through overlapping and conflicting rules and impose large costs on global OTC derivatives markets.
Such provisions have implications for regulatory independence and authority of other countries and have raised concerns regarding the primacy of home country regulators. Though there is recognition of substituted compliance, there is lack of clarity on the implementation of such regime.