The Commodity Futures Trading Commission recently issued a no-action letter that exempts foreign exchange prime brokers from some business-conduct rules 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," R. Martin Chavez of Goldman Sachs said at ISDA's Annual General Meeting in Singapore.