FX Swaps Regulation - Comment Letter - FXall - November 29, 2010
Notice and Request for Comments, Determination of Foreign Exchange Swaps and Forwards
November 29, 2010
Summary of the comment letter:
"FX swaps and FX forwards are largely short-duration instruments, reflecting specific dates, amounts and currencies determined by commercial end users and investors. They are largely traded electronically, on transparent electronic systems, and settled through a CLS Bank. The costs to market participants of the swaps clearing and trading requirements of the Dodd-Frank Act would not be offset by corresponding benefits to market participants in the form of greater protection or reduced risk. For these reasons, the Secretary should determine that FX swaps and FX forwards should not be subject to the Dodd-Frank Act's clearing and trading requirements."