FX Swaps Regulation - Comment Letter - Americans for Financial Reform - November 29, 2010

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Dodd-Frank Timeline, FX Swaps Exception to Swaps Regulation, Treasury Department
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.


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