Tag Archives: fx

Documentation: ISDAs, IFEMAs, FEOMAs…oh my!

In light of… 1) The potential for FX forwards and swaps to be given a pass from the definition of "swap" by Treasury; AND 2)  The heightened business conduct standards, in general, that are bound to relate to FX transactions on the heels of the Treasury exemption… One has to wonder whether or not the various "FX … Continue Reading

OTC Currency Forward: A Diagnostic View of Offsetting Positions In the Wake of the Treasury’s Proposed Determination to Exempt FX Forwards.

On May 2nd, we posted a summary (available here) of the Treasury’s proposed determination (available here) to exempt foreign exchange swaps and foreign exchange forwards from the definition of the term “swap” under the Commodity Exchange Act. In this posting, we would like to provide some additional thoughts about the following statement that we made in the May … Continue Reading

Treasury Issues Proposed Determination To Exempt Foreign Exchange Forwards and Swaps From Definition of Swap Under CEA

On April 29th, the U.S. Department of Treasury released a proposed determination that would exempt both foreign exchange swaps (FX Swaps) and foreign exchange forwards (FX Forwards) from the definition of  the term "swap" under the Commodity Exchange Act. The effect of this exemption will be to remove these instruments from the central clearing and trading … Continue Reading

SPOT FX: Say What You Mean, Mean What You Say

Sometimes you run into an issue that is so blatantly obvious -and with such great frequency – that you say to yourself, “I have got to be seeing ghosts – this can’t really be an issue, can it?” The definition of what constitutes “Spot FX” is one of these issues that is on our minds today … Continue Reading