SIFMA Asset Management Group (“SIFMA AMG”) submitted comments to the CFTC requesting interpretive guidance with respect to the status of certain types of FX transactions as bona fide spot foreign exchange transactions. SIFMA further defined the term “swap,” setting forth a distinction between FX spot transactions and FX forwards that included providing guidance as to “securities conversion transactions,” which are entered into in connection with a related foreign securities transaction.
Additionally, SIFMA AMG submitted comments to the CFTC requesting relief for certain External Business Conduct Standards for certain FX Transactions. SIFMA AMG requested that the CFTC extend the date for compliance by SDs and MSPs with external business conduct requirements and other information collection rules when entering into deliverable FX transactions with a settlement cycle of no more than seven local business days after execution.
See: SIFMA AIMG Interpretive Guidance Letter; SIFMA AIMG Relief Request Letter.
See also: SIFMA AMG Submits Comments to CFTC on Cross-Border Phase-in Exemptive Order and Final Interpretive Guidance (August 26, 2013).