GFMA Submits Comments to the US Treasury on the Exemption of Foreign Exchange Swaps and Forwards Under the Dodd-Frank Act

15 November 2010

The Global FX Division (“Global FX Division”) of SIFMA, AFME and ASIFMA appreciates the opportunity to share our views on the appropriateness of an exemption for foreign exchange (“foreign exchange” or “FX”) swaps and foreign exchange forwards from the definition of a “swap” under the Commodity Exchange Act (the “CEA”) pursuant to the authority granted to the Secretary of the Treasury (the “Secretary”) under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. For the reasons discussed in this letter, we strongly believe that an exemption is warranted.

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