Cross-Border Fragmentation of Global OTC Derivatives: An Empirical Analysis

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

Response to BoE on Systemic Stablecoins

On February 10, ISDA responded to the Bank of England’s (BoE) consultation on a proposed regulatory regime for sterling-denominated systemic stablecoins. In the response, ISDA highlights that any regulatory framework should be assessed through the lens of prudent risk management...

SwapsInfo Full Year 2025 and Q4 2025

Trading activity in interest rate derivatives (IRD) and credit derivatives increased in 2025, reflecting shifting monetary policy expectations and broader market conditions. IRD traded notional rose by about 46% year-on-year, led by an increase in overnight index swaps (OIS). Index...

Maintaining Focus on Basel III Endgame Recalibration

In its original form, the US Basel III endgame proposal would have resulted in disproportionate increases in capital for trading book activities, forcing banks to make difficult choices about their participation in certain businesses. After two-and-a-half years, a revised proposal...