Overall, 58% of respondents stated that they have a formal written policy
for managing foreign exchange. While not a huge change, this figure is an
increase from a 54% result in 2009. Eighty percent of public companies
reported having formal policies, while only 42% of private companies
responded in the affirmative. Likewise, larger companies, with revenue
in excess of $500 million, are more likely to have formal policies, as 85%
meeting this revenue criteria stated they have an FX policy. Conversely, only
39% of companies with revenues of less than $500 million have a policy.
Our continuing conclusion is that public companies, more accustomed to a
Sarbanes-Oxley controls environment and additional public scrutiny, are more
likely to implement formal policies that describe the responsibilities for FX
risk management and establish appropriate controls and authority for such
actions. Nonetheless, we remain surprised that having a formal policy is not
more prevalent.