Comment Text:
RE: Foreign currency forward contracts
Our company operates group tours to countries outside of the United States. Many of our expenses for these tours are denominated in a foreign currency. We use foreign currency forward contracts to lock in current exchange rates for future expenses, which protects both our company and our customers from exchange rate fluctuations. This strategy is essential if we are to be able market the tour to our U.S. customers at a guaranteed price in U.S. dollars.
It is our understanding that the Dodd-Frank Act defines foreign currency forward contracts as "swaps," thereby prohibiting them.
For the reasons stated above, we urge the Commission to exempt foreign currency forward contracts from the restrictive rules applied to "swaps" under the Dodd-Frank Act.
