In favour of the Treasury’s proposed exemption
In contrast to the US Treasury's tightly argued paper justifying an exemption from mandatory central counterparty (CCP) clearing for FX swaps and forwards, Stanford University professor Darrell Duffie's rebuttal is full of vagueness, impression and lacunas.
This is typified by his declaration that he has "not seen any effective argument concerning why FX markets should be exempted from Dodd-Frank requirements that are unrelated to clearing". Yet the Treasury paper addresses only one part of the
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