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Relief from Obligation to Provide Pre-Trade Mid-Market Mark for Certain Forex Transactions
21 December 2012
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The CFTC granted limited no-action relief to swap dealers and major swap participants (together, Swap Entities) from the obligation to disclose a pre-trade mid-market mark (PTM) to their counterparty when entering into certain foreign exchange transactions.
The relief applies to forex swaps, forwards and options that, by their terms, are physically settled, where each currency is included among the top 13 deliverable currencies (by volume) and where the stated maturity is one year or less, for swaps and forwards, and six months or less, for options.
The relief is applicable only if (1) real-time tradeable bid and offer prices for the transaction are available electronically to the counterparty and (2) the counterparty agrees in advance that the Swap Entity need not disclose a PTM.
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