Footnote 88 and Market Fragmentation: An ISDA Survey

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

IRD Trading in the US, EU and UK

This research note analyzes changes in interest rate derivatives (IRD) trading activity in the US, EU and UK from 2021 to 2024. It examines how central bank interest rate policies influenced IRD trading volumes and how the composition of IRD...

Response to ESMA on Clearing Threshold Regime

On June 16, ISDA responded to the European Securities and Markets Authority's (ESMA) consultation on the new clearing threshold (CT) regime. The new CT regime, based on uncleared positions, was introduced in the context of the European Market Infrastructure Regulation...