“There you go again….”

Back in the 1980 presidential campaign, Ronald Reagan used this phrase to great effect to fend off criticism that was untrue or exaggerated. Today, it’s a phrase we think about saying often, particularly when it comes to news reports about the OCC’s Quarterly Report on Bank Trading and Derivatives Activities.

The 2011 second quarter edition is just out and, as usual, it’s creating some misperceptions that need to be clarified. The New York Times, for example, reported on it and said that “The nation’s four biggest banks… are the biggest players, holding roughly 95 percent of the industry’s total exposure to derivatives.”

As we’ve noted in the past, the OCC report only covers part of the US market. The data includes derivatives exposures of US dealers and US subsidiaries of non-US dealers. But it does not include exposures arising from transactions between a US firm and a non-US dealer.

Even more importantly, the OTC derivatives market is global, with competitors from all geographic sectors. On a global basis, the five largest US-based dealers held 37 percent of total derivatives notional according to an analysis ISDA did last year. The G14 group of dealers (the 14 largest) held 82 percent of total notionals outstanding.

The depth and breadth of competition in OTC derivatives is also supported by data from SwapClear, which requires members to have at least $1 trillion in notional outstanding. There are at last count 38 separate dealer/members who meet this criterion.

This leads us to ask: which other global markets have as many firms competing for business as this one?

Recognition of Cross-product Netting is Critical

US regulators are in the process of making important changes to the regulatory capital framework by proposing modifications to the enhanced supplementary leverage ratio, which should help stop it from acting as a non-risk-sensitive constraint on bank capacity – a...

ISDA, GFXD Response to FCA on SI Regime

On September 10, ISDA and the Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association responded to the Financial Conduct Authority's (FCA) consultation paper CP25/20 on the systematic internalizer (SI) regime for derivatives and bonds. ISDA and the...

ISDA Response on Clearing Costs

On September 8, ISDA responded to consultation by the European Securities and Markets Authority (ESMA) on a draft regulatory technical standard on clearing fees and associated costs (article 7c(4) of the European Market Infrastructure Regulation (EMIR)). In the response, ISDA...