SIFMA’s Asset Management Group (AMG), Investment Company Institute (ICI), the Managed Funds Association (MFA) and Investment Adviser Association provide comments to the Commodity Futures Trading Commission (CFTC) to explain the impracticality of registrations based on the inclusion of FX Forwards and Swaps if Treasury ultimately ends up exempting those products from the definition of “swap” after October 12, 2012. Many entities must register with the CFTC on October 12, 2012. SIFMA AMG urges the CFTC not to treat FX Forwards and Swaps as “swaps” until the Treasury makes its final determination.

Related:  SIFMA AMG and Other Associations Submit Comments to the Treasury on FX Forwards and FX Swaps Determination, September 28, 2012