Well before the Dodd-Frank Wall Street Reform and Consumer Protection Act became law in July, financial industry officials turned their attention and concerns toward the aftermath – the months of regulatory rulemaking that would define how the act’s many provisions would ultimately be enforced. This process added a layer of unpredictability on top of the legislative outcome. But if the first implementation of a Dodd-Frank mandate, by the Commodity Futures Trading Commission, is any indication, then industry lawyers and lobbyists might have reason to anticipate flexibility and restraint on the part of the regulators.

CFTC showed its Dodd-Frank hand for the first time in a final rule on retail over-the-counter foreign exchange transactions, published August 30 in the Federal Register and taking effect October 18. It was not the biggest forex industry news of that last quiet week before Labor Day in the U.S.

Overshadowing it was the Bank for International Settlements’ preliminary findings from its triennial survey of the global foreign exchange market, showing that daily turnover had reached $4 trillion as of April, 20 percent higher than in April 2007. ....



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