“The Determination’s conclusions and reasoning were primarily based on the classic “if it ain’t broke, don’t fix it” chestnut that, in our view, has been too frequently absent from the overall Dodd-Frank Act regulatory process.”

GLOBALCAPITAL INTERNATIONAL LIMITED, a company

incorporated in England and Wales (company number 15236213),

having its registered office at 4 Bouverie Street, London, UK, EC4Y 8AX

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“The Determination’s conclusions and reasoning were primarily based on the classic “if it ain’t broke, don’t fix it” chestnut that, in our view, has been too frequently absent from the overall Dodd-Frank Act regulatory process.”

—Peter Green, partner at Morrison & Foerster in London, on the U.S. Treasury’s decision to exempt fx forwards and swaps from the clearing obligation under Dodd-Frank.

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