The U.S. Treasury finallyannounced late last week that it was exempting foreign exchangeforwards and swaps from Dodd-Frank clearing requirements, but thereare still several issues outstanding that could affect corporateend users of derivatives.

FX forwards and swaps remain subject to requirements includingtrade reporting, the Commodity Futures Trading Commission'santi-evasion authority, which aims to keep Wall Street fromtweaking cleared FX products to receive exempt status, andDodd-Frank's business conduct rules, according to an analysis byCadwalader Wickersham & Taft.

In its announcement, Treasury said participants in FX forwardsand swaps know their own and their counterparties' paymentobligations and their full exposures through the life of thecontract, which distinguishes them from a handful of other FXderivatives that most likely will have to be cleared, including FXoptions, currency swaps, cross-currency swaps, contracts fordifferences, foreign-rate agreements and non-deliverable forwards(NDFs)