Exchange Rate Analysis

Treasury uses its Global Exchange Rate Assessment Framework (GERAF) to assist in its work on exchange rates. 

Global Exchange Rate Assessment Framework Methodology

GERAF is a flexible tool created to assess currency valuations.   This model-based framework provides a multilaterally consistent method for assessing external imbalances, exchange rate misalignments, and the role of policy in contributing to both.  Further detail on GERAF is provided in the methodology paper.


One of Treasury’s applied uses of GERAF is to assess currency valuations in the context of countervailing duty proceedings when requested by the Department of Commerce.  As described in the final modification of 19 CFR 351.528, published in the Federal Register in February 2020, Commerce will request that Treasury provide its evaluation and conclusion as to the extent of any undervaluation in the context of a countervailing duty proceeding in which Commerce is investigating whether there is a potential subsidy resulting from currency undervaluation.  Treasury will provide its assessment of whether and to what extent a currency is undervalued against the U.S. dollar as a result of government action on the exchange rate.  Commerce intends to defer to Treasury’s expertise with respect to currency undervaluation.

The legal framework governing countervailing duty proceedings and the statutes under which Treasury provides periodic reports to Congress reviewing the macroeconomic and foreign exchange policies of major U.S. trading partners are distinct, involving different legal criteria.  Further information about Treasury’s periodic reports to Congress, including the authorizing statutes for these reports, can be found here.

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