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
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A Critical Step to Efficient Treasury Clearing
By the end of this year, the first prong of the Securities and Exchange Commission’s (SEC) Treasury clearing mandate will come into force. This is part of a regulatory effort to make the financial system more robust, but it will...
Joint Response to FCA and HMT Consultations
On January 16, ISDA and UK Finance responded to both the consultation on streamlining the UK European Market Infrastructure Regulation (UK EMIR) intragroup regime by the Financial Conduct Authority’s (FCA) and the draft statutory instrument from His Majesty’s Treasury (HMT)....
Key Trends in OTC Derivatives Market H1 2025
The latest data from the Bank for International Settlements (BIS) over-the-counter (OTC) derivatives statistics shows an increase in notional outstanding of OTC derivatives during the first half of 2025 compared to the first half of 2024. Notional outstanding rose across...
Credit Derivatives Trading Activity Q3 2025
This report analyzes credit derivatives trading activity reported in Europe. The analysis shows European credit derivatives transactions based on the location of reporting venues (EU versus UK) and product type. The report also compares European-reported credit derivatives trading activity to...