Earlier this week, the US CFTC approved rules governing the execution of swap transactions. Among the major issues was a proposal to require market participants to seek five price quotes on trades done on a swap execution facility. The Commission ultimately voted to mandate two “request for quotes” (RFQs), with the requirement eventually increasing to three.
The range of headlines (and stories) following the CFTC vote was interesting:
“US in Compromise on Derivatives Trade Rules” (Financial Times)
“Regulators Strike Compromise on New Derivatives Rules” (Wall Street Journal/Dow Jones)
“Big Banks Get Break in Rules to Limit Risks” (New York Times)
“Wall Street Wins Rollback in Dodd-Frank Swap-Trade Rules” (Bloomberg)
“CFTC adopts SEF rule, including RFQ3, voice broking” (Reuters)
Hmmmm. Was it a compromise, a rollback, a break or something else entirely? (It clearly was an adoption of a rule, as Reuters notes.)
Another point of interest: in at least some of the articles, there’s a presumption in favor of requiring five RFQs.
Why? How or why is it “good” to mandate that a derivatives user request a certain number of price quotes from different dealers? And why five?
Shouldn’t this be up to market participants to decide? Particularly since getting a quote is easy enough, given the different ways derivatives users can get or check prices (via phone, terminals, and dealer, broker and other trading systems)?
The flawed assumption is that the client is not qualified to decide for itself whether 2, 3 or 23 quotes are optimal. It also ignores the fact that information has value for the recipient of the quote requests and the client might not want to offer that information to any more counterparties than is appropriate to the situation.
There’s something else that’s interesting: it’s the presumption that these trade execution rules have anything to do with reducing risks in the financial system. Trade execution is about market structure – not systemic risk. If the goal of financial regulatory reform is to reduce systemic risk, shouldn’t we focus on issues that affect it, like regulatory capital, clearing, margining and regulatory transparency?
Shouldn’t we also avoid mandating “more” to customers when it really means less, and just leave it to them to decide how much is enough?
# # #
Latest
ISDA DTF Hong Kong: Steven Kennedy Remarks
ISDA Derivatives Trading Forum Hong Kong November 12, 2026 Opening Remarks Steven Kennedy Global Head of Public Policy, ISDA Good morning, and welcome to the ISDA Derivatives Trading Forum. It’s great to be here in Hong Kong – thanks for...
2026 FX Definitions: Act Now
On November 22, 2027, the 2026 FX Definitions will come into effect. From that point, these definitions will become the market standard for all cleared and new non-cleared FX derivatives, and the Swift messaging service will halt its support of...
IRD Trading in Mainland China and Hong Kong
This report examines interest rate derivatives (IRD) trading activity in mainland China and Hong Kong in the first half of 2026. Onshore renminbi (RMB) IRD traded notional in mainland China rose to $3.4 trillion in the first half of 2026,...
ISDA In Review – October 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in October 2026.
