Tag Archives: Derivatives

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This Week in Wall Street Reform

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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.

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AFR Comments on Proposal to Reopen Derivatives Regulations

AFR submitted a comment in response to the CFTC’s request for views on their overall proposed structure for regulating swaps and derivatives. The comment raised several issues concerning conflicts of interest in ownership and management of key areas of derivatives infrastructure, like clearinghouses and swaps data repositories. AFR also raised potential problems with definitions of “commercial risk” that could permit evasion of regulations.