The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Company Institute (ICI) provide comments to the Commodity Futures Trading Commission (CFTC) requesting that the CFTC extend the date for compliance with their swap trading relationship documentation rules (the Final Swap Documentation Rule) for foreign exchange swaps and foreign exchange (FX) forwards exempted from the definition of swap by the U.S. Secretary of the Treasury (Exempt FX Transactions) until at least July 1, 2014.

SIFMA AMG and the ICI feel this extension is necessary given the lack of market awareness of application of the Final Swap Documentation Rules to Exempt FX Transactions.  Additional time will allow asset managers to continue to focus their efforts on compliance with CFTC rules, including the Final Swap Documentation Rules for swaps, while they work on obtaining client consents and putting in place documentation to be compliant with the Final Swap Documentation Rules for Exempt FX Transactions.