The Commodity Futures Trading Commission recently issued a no-action letter that exempts foreign exchange prime brokers from some business-conduct rules that were mandated by the Dodd-Frank Act. "The external business-conduct standards have an important and valuable intention. ... But the rule also mandates pre-trade disclosures from the prime brokers to the clients. This is a great idea, except prime brokers don't see the trade until after it is done, so it is just not possible," said R. Martin Chavez of Goldman Sachs.

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