Staff is considering recommending that the Commission codify the staff intrepretation in CFTC Staff Letter 25-10 that (1) foreign exchange window forwards that may be settled on a series of specified dates (Window FX Forwards), should be considered foreign exchange forwards as defined in section 1a(24) of the Commodity Exchange Act (CEA) and, thus, exempt from the swap definition in section 1a(47) of the CEA and Commission regulation 1.34 pursuant to the Treasury Determination; and (2) clarify that package Spot FX transactions described in Staff Letter 25-10 should not be considered to be foreign exchange swaps as defined in section 1a(25) of the CEA or otherwise as swaps as defined in section 1a(47) of the CEA, provided that such transactions are executed, confirmed, and settled as individual bona fide spot transactions (i.e., transactions that settle via an actual delivery of the relevant currencies within two business days of the transaction date or within the customary timeline for the relevant spot currency market).