In December 2013, ISDA published "Footnote 88 and Market Fragmentation: An ISDA Survey" (see December 18, 2013 on this page). The Survey’s findings revealed that the October 2, 2013 effective date for Swap Execution Facility (SEF) compliance, the definition of a US person and the Footnote 88 interpretation are clearly having a disruptive impact on OTC derivative trading volumes. Market participants reported that cross-border liquidity has fragmented along US person and non-US person lines. In January, ISDA completed this new analysis that builds on our earlier work and aims to empirically characterize the composition of and changes to cross-border pools of liquidity following the October implementation date. To accomplish this, we use monthly 2013 clearing and reporting data for US dollar and Euro interest rate swaps (IRS) for our use-case.
Documents (1) for Cross-Border Fragmentation of Global OTC Derivatives: An Empirical Analysis
Latest
ISDA/ASIFMA Request Clarifications on RBI IRD Master Directions
On February 11, 2026, ISDA and ASIFMA submitted a joint letter to the Reserve Bank of India (RBI) requesting clarifications on Master Direction – RBI (Rupee Interest Rate Derivatives) Directions, 2025 (FMRD.DIRD.No.06/14.03.046/2025-26) related to reporting data of IRD transactions entered...
ISDA In Review – February 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in February 2026.
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
ISDA Market Practice Note for the Rebasing of European Inflation Indices
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