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The U.S. Commodity Futures Trading Commission (CFTC) regulates non-deliverable forwards (NDFs) as “swaps” under the Dodd-Frank Act. In this capacity, the agency has authority to mandate that NDFs must be cleared through a regulated central clearing counterparty, also known as a clearinghouse or a CCP. For some currencies, such a rule seems to be coming soon. And although it won’t affect the majority of companies, corporate treasurers—especially those who preside over complex global organizations—should understand its intricacies.

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