Don't wait until the last minute to adhere to the ISDA March
2013 DF Protocol ("DF Protocol 2.0")!
End-users who trade non-spot FX transactions and do not have an
existing master agreement in place with their swap dealers must
adhere to DF Protocol 2.0 (or an equivalent swap trading agreement)
before December 31, 2013. Failure to adhere to DF Protocol 2.0, or
enter into an equivalent master agreement by December 31, 2013,
could significantly impact corporate FX trading.
Historically, corporate end-users often traded FX transactions
without any master agreement, and dealers generally provided
favorable terms for the credit risk associated with the
transactions. The financial crisis and the Dodd-Frank Act changed
much of this practice. The financial crisis caused dealers to
reconsider their credit risk policies and procedures for swap
trading. Furthermore, on September 11, 2012, the CFTC issued final
rules regarding, among other things, swap trading