Global Correspondence

GFMA Submits Comments to the CFTC on Confirmation, Portfolio Reconciliation and Portfolio Compression Requirements

The Global FX Division provides comments to the Commodity Futures Trading Commission (CFTC) on confirmation, portfolio reconciliation and portfolio compression requirements for swap dealers and major swap participants, RIN 3038-AC96 – 17 CFR Part 23.  The proposal would implement provisions of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The Global FX Division notes there are some specific challenges that face the foreign exchange industry when compared to other asset classes, namely the high volume of transactions and the wider universe of participants. These arise because the foreign exchange market forms the basis of the global payments system. These two issues provide a practical challenge in ensuring that all relevant trades and counterparties are able to comply with any proposed rules.

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