Global Correspondence

GFMA and ABA Submit Comments to US Regulators on Retail Foreign Exchange Transactions

The Global FX Division of GFMA and the American Bankers Association (ABA) provide comments to multiple U.S. federal regulators requesting clarification or, in the alternative, relief regarding certain foreign exchange (FX) transactions with counterparties that are not within the definition of “eligible contract participants,” or “ECPs,” under the Commodity Exchange Act. Specifically, the groups ask that the U.S. federal regulators confirm that FX transactions that are solely incidental to, and are initiated for the sole purpose of permitting a client to complete a transaction in, a foreign security are not subject to the regulators’ retail FX rules developed to comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act).

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