Yesterday, the Foreign Exchange Professionals Association (FXPA) filed a comment letter with the CFTC in connection with its recent proposal to maintain the current $8 billion de minimis threshold for swap dealer registration.

In its comment letter, which is available here: https://comments.cftc.gov/PublicComments/ViewComment.aspx?id=61753&SearchText= in addition to supporting the CFTC’s proposal to keep the de minimis threshold in swap dealing activity for swap dealer registration at $8 billion; the FXPA also confirmed its support for excepting non-deliverable forwards (NDFs), as well as exchange-traded swaps, whether on SEFs or DCMs, and cleared swaps, from calculations of firms’ swap dealing activity for purposes of the de minimis threshold.

“The FXPA appreciates the opportunity to comment on the CFTC’s recent proposal to maintain the de minimis threshold for swap dealer registration at $8 billion,” says FXPA President, John Shay. “We are also grateful to be able to draw upon the collective views of our broad membership of participants in the foreign exchange market to support regulatory changes that will further the goal of ensuring that our financial markets are fairly and properly regulated.”