Manufacturers Applaud Treasury Determination on FX Swaps

By November 19, 2012Taxation

The NAM joined the Coalition for Derivatives End-Users today in applauding the determination by the U.S. Treasury Department late last week that foreign exchange (FX) swaps should not to be regulated as “swaps” under the Dodd-Frank Wall Street Reform Act. The NAM and the Coalition called on Treasury to make this final determination two years ago in comments stating that as FX swaps and forwards “do not materially contribute to systemic risk” that they should be granted an exemption from additional regulation. This determination is a clear acknowledgement that over-regulating in this area would be detrimental to end-users’ efforts to manage risk through FX swaps and forward.

Manufacturers have long used derivatives to hedge business risk and the granting of an exemption for these swaps by Treasury is a positive step forward. We hope that other agencies will follow suit and ensure that as they continue to implement Dodd-Frank –particularly in the areas of margin requirements, inter-affiliate trades and cross-border rules –they do not create new costs and regulatory burdens on end-users.  We appreciate Treasury’s granting of an exemption for FX swaps and forwards.

Carolyn Lee

Carolyn Lee

Executive Director of The Manufacturing Institute at The Manufacturing Institute
Carolyn Lee is Executive Director of The Manufacturing Institute, the non-profit affiliate of the National Association of Manufacturers (NAM), the nation’s largest industrial trade association. Carolyn drives an agenda focused on improving the manufacturing industry through its three centers: the Center for the American Workforce, the Center for Manufacturing Research, and the Center for Best Practices.

In her role, Carolyn leads the Institute’s workforce efforts to close the skills gap and inspire all Americans to enter the U.S. manufacturing workforce, focusing on women, youth, and veterans. Carolyn steers the Institute’s initiatives and programs to educate the public on manufacturing careers, improve the quality of manufacturing education, engage, develop and retain key members of the workforce, and identify and document best practices. In addition, Carolyn drives the agenda for the Center for Manufacturing Research, which partners with leading consulting firms in the country. The Institute studies the critical issues facing manufacturing and then applies that research to develop and identify solutions that are implemented by companies, schools, governments, and organizations across the country.

Prior to joining the Institute, Carolyn was Senior Director of Tax Policy at the NAM beginning in 2011, where she was responsible for key portions of the NAM’s tax portfolio representing the manufacturing community on Capitol Hill and in the business community and working closely with the NAM membership. She served as the Director of Legislative and Government Affairs at the Telecommunications Industry Association, Manager of State and Federal Government Affairs for 3M Company, and in various positions on Capitol Hill including as Legislative Director for former U.S. Senator Olympia Snowe (R-ME), and as a senior legislative staff member for former U.S. Rep. Sue Kelly (R-NY).

Carolyn is a graduate of Gettysburg College in Gettysburg, Pennsylvania graduating with a B.A. in Political Science. She resides in Northern Virginia with her husband and three children.
Carolyn Lee

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