I think that in FpML 4.1 the equitySwap product element, even though it is named equity swap, should be able to represent return type swaps. The element was renamed in FpML 4.2 to returnSwap but its content model didn’t change much from 4.1 to 4.2. Actually, the element was renamed because there was a mismatch between content and product name. As I said, the element was named equitySwap in 4.1 but it was actually representing a return swap. So take a look at the equitySwap element in FpML 4.1 because besides the difference in product name, it may be able to cope with your requirements. Hope this helps. -Marc