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The Commodity Futures Trading Commission’s Market Participants Division and Division of Market Oversight today issued an interpretative letter providing the Divisions’ views on the characterization of certain FX transactions as being swaps, foreign exchange forwards, or foreign exchange swaps, in each case, as defined in the Commodity Exchange Act.
Specifically, the interpretative letter states:
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Window FX Forwards, as described in the letter, should be considered to be “foreign exchange forwards;” and
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Package FX Spot Transactions, as described in the letter, should not be considered to be “foreign exchange swaps” or “swaps.”
