SIFMA’s Asset Management Group (AMG), Investment Company Institute (ICI), the Managed Funds Association (MFA) and Investment Adviser Association provide comments to the Commodity Futures Trading Commission (CFTC) and requests the Treasury to make a prompt final determination on its proposal to exempt FX Products from the definition of “swap” under the Commodity Exchange Act (CEA). The letter outlines the substantial unintended consequences on the impending registration and compliance deadlines for commodity trading advisors (CTAs), commodity pool operators (CPOs) and major swap participants (MSPs) if the Treasury does not act.

Related: SIFMA AMG and Other Associations Submit Comments to the CFTC on FX Forwards and FX Swaps Determination, September 28, 2012