The road to hell is paved with good intentions, Samuel Johnson famously said. He probably was not thinking of the Dodd-Frank Act when he said it, but the well-intentioned statute is driving dealers to despair over its treatment of certain foreign exchange derivatives. Of particular concern are definitions that threaten to force firms to into dealer status when they could hardly be considered systemic.

“We think this issue was an accident; we don’t think it was intentional. We have spoken with