Earlier this year, the CFTC required that swap execution facilities (SEFs) with temporary SEF registration status come into full compliance with all applicable SEF rules beginning on October 2, 2013. Originally, those rules were thought to apply only to transactions that would be required to trade on a SEF. However, the language of the rule’s Footnote 88 implies that rules would apply to any transaction the SEF offered, whether or not that transaction is mandated to trade on a SEF. These concerns prompted ISDA to conduct a SEF Market Fragmentation Survey to obtain a clear picture of potential market disruption or fragmentation resulting from SEF rule implementation. This Research Note examines the results of that survey.
Documents (1) for Footnote 88 and Market Fragmentation: An ISDA Survey
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.
