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ARTICLE · 30 DECEMBER 2013

Swaps End-User Update: FX Swap Trading Reminder For End-Users

Don’t wait until the last minute to adhere to the ISDA March 2013 DF Protocol!

United StatesFinance and Banking

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

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