CFTC Registration and SDR Reporting
Under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, FX swaps, FX forwards (with limited exemptions), NDFs and FX options are subject to the CFTC swap definition and require reporting to a registered swap data repository. The Securities and Exchange Commission and the Federal Reserve co-ordinate with the CFTC on the overlapping derivatives perimeter. U.S. Bank is a registered swap dealer; SinglePoint reports qualifying trades to a CFTC-registered SDR on behalf of American clients automatically.
Deliverable spot FX and deliverable FX forwards are generally exempt from the swap definition under the US Treasury's determination. American end-users of FX often qualify for the CFTC end-user exception to mandatory clearing and exchange trading, preserving bilateral SinglePoint dealer-client execution.


