The Global FX Division of SIFMA, AFME and ASIFMA provide comments to the U.S. Department of Treasury on the appropriateness of an exemption for foreign exchange (FX) swaps and foreign exchange forwards from the definition of a “swap” under the Commodity Exchange Act (the “CEA”) pursuant to the authority granted to the Secretary of the Treasury (the Secretary) under the Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act). The Associations strongly believe that an exemption is warranted.