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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Key IRD Trends from BIS 2025 Survey
This paper highlights changes in over-the-counter (OTC) interest rate derivatives (IRD) markets between April 2022 and April 2025, based on data from the Bank for International Settlements (BIS) Triennial Central Bank Survey. The survey provides a comprehensive view of global...
RMB IRD Growth in Mainland China & Hong Kong
This report analyzes interest rate derivatives (IRD) activity in mainland China and Hong Kong, with a particular focus on renminbi (RMB)-denominated IRD. It examines market growth, structure and integration across onshore and offshore centers, and places these developments within the...
ISDA and SIFMA Comment on CFTC Proposed Revisions to Business Conduct and Swap Documentation Requirements
On October 24, 2025 ISDA and SIFMA submitted comments to the CFTC on its proposed Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants. The proposal covers amendments to requirements related to external business...
