AFR Opposes Exempting Forex Swaps and Forwards from Clearing and Exchange Requirements
AFR submitted a joint comment with Professor Michael Greenberger of the University of Maryland on Treasury proposal to exempt foreign exchange swaps and forwards from clearing and exchange trading requirements under Dodd-Frank. The letter pointed out that Treasury had not provided any evidence supporting its case that foreign exchange derivatives did not pose systemic risk, and in fact there is very strong evidence from the 2008 financial crisis and today that they do pose such risks.