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Impact Of RBI Circular On Currency Trading For Retail Investors And Market Dynamics

The Reserve Bank of India’s latest announcement related to currency trading has taken the retail traders’ world by surprise. The RBI's move aims to streamline and enhance transparency in the foreign exchange market while ensuring prudent risk management practices among market participants. Let’s learn in detail what the RBI said, what it means and how it will impact the retail currency traders’ market! 


How did it begin?

In January, 2024, the Reserve Bank of India (RBI) issued a circular tightening the rules on forex derivative contracts involving the rupee, stating these can only be used for hedging contracted exposure. The circular specified that trading in currency derivatives up to $100 million equivalent across all currency pairs is permitted only with a valid underlying contracted exposure. Basically, the RBI said that if traders want to trade in currency contracts, they can only do it if they have a real reason for it, like needing to protect themselves from changes in currency values. This is called "hedging contracted exposure." Moreover, the central bank also put a boundary limiting traders’ trading limit which is up to $100 million and that too across all currencies combined! Previously, traders were allowed to trade in currency contracts without needing a specific reason, but now they have to have a valid reason for it.


But why did the RBI come up with this idea? 

This move comes as part of the RBI's efforts to minimize volatility in the rupee ahead of India's bond inclusion in global indexes from June ’24. Another reason is that the RBI wants to limit traders doing speculative trading. The implementation of these new regulations has been deferred to May 5th, but the RBI has reiterated that its policy approach towards exchange traded currency derivatives (ETCDs) remains unchanged, emphasizing consistency in the regulatory framework. This regulatory tightening aligns perfectly with the RBI's broader foreign exchange management policy, aiming to ensure that currency derivatives trading primarily serves the purpose of hedging forex risk, reducing speculative activity in the market. 


What is the RBI Circular? 

The RBI announced its move towards trading in currency derivatives by the medium of two circulars, namely - ‘Circular No. 147’ and ‘A.P. Circular No. 13’. Let’s first hear what the circulars have to say and then break it down for our own understanding. 


Circular No. 147

In terms of the present regulatory framework, domestic participants in the currency futures and exchange traded options markets are not required to have any underlying exposure while requirement of underlying is mandatory for taking a position in the over-the-counter (OTC) derivatives markets. With a view to bringing about an alignment between the two markets, henceforth domestic participants in the currency futures and exchange traded currency options will be subject to the following terms and conditions:

  • Domestic participants shall be allowed to take a long (bought) as well as short (sold) position up to USD 10 million per exchange without having to establish the existence of any underlying exposure. For the purpose of convenience, exchanges may prescribe a fixed limit for the contracts in currencies other than USD such that the limit is within the equivalent of USD 10 million.
  • Domestic participants who want to take a position exceeding USD 10 million in the ETCD market will have to establish the existence of an underlying exposure. 

Okay, let's simplify this:

Current Situation: Presently, if you're trading in currency futures and exchange-traded options (basically, studying and forecasting on where currency prices will go), you don't need to prove that you actually have any reason or need to trade. But if you're trading in over-the-counter (OTC) derivatives (similar to exchange-traded options, but traded directly between parties rather than on an exchange), you do need to prove you have a real reason for trading.

New Rule: To make things fairer and more consistent, RBI said that it is changing the rules for trading in currency futures and exchange-traded options. Here's how it works:

  • You can make trades up to $10 million per exchange without needing to prove you have a specific reason for trading. This applies whether you're forecasting the currency will go up (long position) or down (short position).
  • If you want to make a trade larger than $10 million, then you do need to prove you have a real need or reason for making that trade.

So, basically, they're making it so that if you want to trade a lot of money, you need to show you're doing it for a good reason, but if it's a smaller amount, you can trade without needing to prove anything.

Now. for A.P. Circular No. 13, you can download this directly by clicking here. 

Or you can just read the explanation below and understand it in a simpler way. 

The A.P. Circular No. 13 lays directives regarding currency trading used for hedging purposes. In this circular, the RBI pointed out two major concerns viz - ‘Not hedging the same exposure twice’ and ‘Aligning value and tenor with the Underlying Exposure’. Let’s understand what does this say:


Not hedging the same exposure twice: This means that users (traders or investors) can't use multiple derivative contracts to protect themselves against the same risk. For example, if someone is using one derivative contract to protect against a drop in the Indian rupee's value, they can't use another contract for the same purpose. 

Aligning Value and Tenor with the Underlying Exposure: The "value" refers to the amount of money involved in the derivative contract, while "tenor" refers to the duration or maturity of the contract. This guideline means that the value and duration of the derivative contract should match the actual risk or exposure it's meant to protect against. If there are changes in the underlying risk, like a change in the amount of money involved or how long it lasts, then adjustments need to be made to the derivative contract to keep everything in line. 


Impact on Retail Traders

The circular's ramifications are multifaceted. Firstly, retail traders face potential disruptions to their trading activities and financial strategies, potentially leading to missed profit opportunities and financial challenges. Consequently, there may be a shift towards alternative investments, necessitating adaptation to different market dynamics and risks.

While retail traders contribute less to market liquidity compared to institutional players, their absence could still impact the dynamics of less popular currency pairs or trading during off-peak hours. Moreover, the circular introduces penalties for failing to square off positions by the prescribed deadline, affecting large hedge funds and quant-based funds. The resultant drop in open interest due to positions not being rolled over suggests a market shift towards dominance by hedgers, such as exporters, importers, and Foreign Portfolio Investors (FPIs).

This transformation may also reverberate across brokers and trading platforms, prompting adjustments in business models, employment, and the availability of trading services. Additionally, the halt in trading may signal broader regulatory or economic concerns, potentially shaking market confidence and indicating financial market instability or significant impending changes.


The RBI circular on currency trading represents a significant shift in the regulatory landscape, with profound implications for retail investors, and the broader market itself. Retail traders will need to navigate these changes by adapting their strategies and possibly exploring new markets. The market dynamics are likely to shift towards more hedging activities, and brokers along with trading platforms may need to reconsider their business models in response to these regulatory changes. This situation underscores the importance of adaptability and the need for a comprehensive understanding of regulatory environments in financial market participation.


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