Dodd-Frank and FX... a case of unintended consequences?

5 May 2011

David Field

So they decided to exclude FX derivatives from the requirement to clear centrally.  A case study in unintended consequences?

The effect of a pair of interest rate swaps can be synthesised through a non-deliverable FX forward trade combined with a long dated cross currency swap. So if a bank chooses to trade a synthetic IR products as an FX derivative structure, they are able to completely bypass Dodd-Frank, and avoid the costs of CCP membership, margin collateral and infrastructure consequences.

So at a stroke this decision will drive interest rate swaps, the largest portion of the OTC market, out of the reaches of the legislation. Is that really what they wanted? I don't think so.


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David Field

Specialist in Clearing and Collateral Management
David Field

This decision will drive interest rate swaps, the largest portion of the OTC market, out of the reaches of the legislation

David Field

Specialist in Trading and OTC clearing