FX Swaps Regulation - Comment Letter - Americans for Financial Reform - November 29, 2010
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|Proposal Date||Comment Deadline||Proposed Determination||Final Determination|
|October 28, 2010||November 29, 2010||April 29, 2011||November 16, 2012|
Americans for Financial Reform urges U.S. Treasury Secretary Timothy Geithner to not exempt foreign exchange swaps and forwards from the Dodd-Frank definition of swaps. Several arguments are highlighted, including:
- The sheer size of the FX market $4 trillion per day) poses a systemic risk.
- Spot FX settlement platforms exist, but are inadequate, and half of these transactions occur outside the system.
- Counterparty credit, liquidity, and market/price risks are much larger than the industry acknowledges.