The Commodity Futures Trading Commission’s Market Participants Division and Division of Market Oversight issued an interpretative letter setting out their views under the Commodity Exchange Act that Window FX Forwards should be characterised as “foreign exchange forwards” and that Package FX Spot Transactions should not be treated as “foreign exchange swaps” or “swaps.”
Commodity Futures Trading Commission 2025-04-09
Commodity Futures Trading Commission staff interpretative letter treats Window FX Forwards as foreign exchange forwards and excludes Package FX Spot Transactions from swap status
The Commodity Futures Trading Commission's Market Participants Division and Division of Market Oversight issued an interpretative letter under the Commodity Exchange Act. The letter clarifies that Window FX Forwards are to be characterized as "foreign exchange forwards," while Package FX Spot Transactions should not be treated as "foreign exchange swaps" or "swaps."