Posted on February 21, 2014 by Paul Blank
This week saw the introduction of mandatory execution on new SEF platforms for certain standardised interest rate swaps. Such swaps will no longer be executed bilaterally between banks and their clients, but rather must be executed anonymously on SEFs.
The move to SEF trading has however been tentative, with many buy-side firms holding back, nonetheless by midweek some 74% of the 372 IRS trades were being executed on SEFs, according to data from Clarus. Although there are 23 newly registered SEFs , the majority of business so far has tended to flow through to the incumbent inter-dealer platform SEFs.
But what about single-dealer platforms (SDP), how are banks managing the migration to SEF trading? Continue reading →
Filed under: CEP, CFTC, Dodd Frank, OTC, Paul Blank, Regulation, SEF, SWAPS | 1 Comment »
Posted on January 17, 2014 by Paul Blank
The CFTC has just approved Javelin’s “self certified” list of Made Available to Trade (MAT) interest rate swap contracts. This means that from 15th February, in 30 days time, these products will be mandated to trade on SEFs or DCMs, and nowhere else (see below for full list of swaps).
However, it appears that Commissioner Scott D. O’Malia has concerns about the legality of the determination, as he has just released the following statement on the Made Available-to-Trade Determination. As we say, you really couldn’t make this stuff up!
It is hard to imagine a federal agency regulatory process that is more flawed than the Made Available-to-Trade (“MAT”) determination. The Commission staff has certified all interest rate benchmarks and related packaged transactions for mandatory trading on swap execution facilities (“SEFs”) or designated contract markets (“DCMs”), while at the same time, stated that it will consider some future action for all packaged transactions. And to complicate things further, the Commission has been excluded from a major regulatory decision that significantly reshapes current market infrastructure.
It gets worse, as he then goes on to say that:
Continue reading →
Filed under: CFTC, Paul Blank, Regulation, SEF, SWAPS | 2 Comments »
Posted on December 10, 2013 by Paul Blank
Five US agencies have released the final version of section 619 of the Dodd-Frank Act that governs proprietary trading, otherwise known as the “Volcker Rule”.
The five agencies being: Board of Governors of the Federal Reserve System, Commodity Futures Trading Commission, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and the Securities and Exchange Commission.
The rules would generally prohibit banks from:
- Engaging in short term proprietary trading of securities, derivatives, commodity futures and options on these instruments for their own account
- Owning, sponsoring, or having certain relationships with hedge funds or private equity funds, referred to as ‘covered funds.’
The rules provide exemptions for certain activities which include; market making, underwriting, hedging, trading in certain government bonds, and organising and offering a hedge fund or private equity fund.
The rules however, limit these exemptions if they involve Continue reading →
Filed under: CFTC, Dodd Frank, OTC, Paul Blank, Regulation | 1 Comment »
Posted on December 5, 2013 by Paul Blank
Just finished listing to an interesting webcast on Global OTC market reforms, and where next after the US and SEFs?
Celent analyst Anshuman Jaswal, gave overview of market, SEF volumes to date, and possible differences in regulatory treatment and approach in Europe and Asia.
Some key points form slide deck and a couple of slides below.
SEF and OTFs are critical components in evolution of the market from OTC non-standardised bilaterally cleared to standardised electronically traded and centrally cleared swaps.

Celent slide on shift to standardised swaps
In terms of SEF volumes Continue reading →
Filed under: CCP, CFTC, Dodd Frank, OTC, OTF, Paul Blank, SWAPS, Web trading technology | 2 Comments »
Posted on November 27, 2013 by Paul Blank
The CFTC has issued temporary no action relief until 14 Jan 2014 for Certain Transaction-Level Requirements (see below for full list) for Non-U.S. Swap Dealers.
This relief comes on the back of concerns raised regarding compliance with certain Transaction Level Requirements by overseas based Swaps Dealers (Non-US SD), who enter into swaps with a non-US person, where those swaps are regularly arranged, negotiated, or executed by personnel or agents of the Non-U.S. SD located in the United States.
Prior to the relief, such transactions required Continue reading →
Filed under: CFTC, Paul Blank, Regulation, SEF, SWAPS | Leave a comment »
Posted on November 19, 2013 by Paul Blank
Speaking at SEFCon IV conference in NY this week, Gary Gensler, Chairman of the CFTC said that Bloomberg, TradeWeb and MarketAxess are failing to provide impartial access as required under SEF rules.
The three main platforms, are giving the banks too much control over who their customers buy and sell with, in an attempt to preserve the existing dealer-client structure, and that they need to come inline with the CFTC equal access rules.
“What they are doing right now is a violation of Dodd-Frank and our rules,” he said at an event in New York. “They need to come into compliance,” he said. The limits at Tradeweb, MarketAxess and Bloomberg LP give an advantage to the dealers who created the swaps market in the 1980s, Gensler said. “They’re trying to keep exclusive to the dealers.”
More here on Bloomberg and Risk.Net and of course from Kevinonthestreet
Separately, Continue reading →
Filed under: CFTC, Dodd Frank, OTC, Paul Blank, Regulation, SEF, SWAPS | 1 Comment »
Posted on November 4, 2013 by Paul Blank
Better late than never! The CFTC has granted the CME temporary SEF registration, bringing to 18 the number of platforms that have been granted temporary SEF registration.
The CFTC site has a section showing status of SEF filing applications.
Filed under: CFTC, OTC, Paul Blank, Regulation, SEF, SWAPS, Web trading technology | 1 Comment »
Posted on November 4, 2013 by Paul Blank
Last Friday the CFTC issued a ‘no action letter’ extending until 29th November the ‘time-limited’ relief from certain Swap Data Reporting Requirements for FX Swaps, the products in focus being NDFs and FX Options.
The extension comes on the back of representations, including a very compelling letter from James Kemp, MD of The Global Foreign Exchange Division, setting out the reasons for requesting the extension. Reading the arguments, you can see how ill prepared the majority of SEFs are to assume their obligations, and why market participants are reluctant to migrate trading onto SEFs.
According to the letter:
Key risks which have materialized for the NDF and Options markets since October 2nd including:
- Reduced Legal Certainty for FX Trades Executed on SEFs.
In contrast to the practices developed and implemented by market participants over the past fifteen years to provide legal certainty Continue reading →
Filed under: CFTC, Dodd Frank, FX, OTC, Paul Blank, Regulation, SEF, SWAPS | Leave a comment »
Posted on October 30, 2013 by Paul Blank
TradeWeb TW SEF joins Javelin and TrueEX in submitting the list of swaps they wish to Make Available to Trade (MAT).
Last week, Javelin submitted a long list of MAT Swaps, whilst TrueEX submitted a list of actively trade benchmark swaps.
TradeWeb recognising market sensitivity, also goes for the benchmark listing for their MAT determination, stating that:
“It is in a unique position to observe and quantify market participants’ electronic trading behavior. Due to the breadth of institutions participating on our platforms and the metrics that we can capture from the activity on our platforms, we have been able to develop a very clear picture of the electronic execution of swaps, which allows us to quantify the trading experience of both liquidity takers and liquidity providers”. Continue reading →
Filed under: CCP, CFTC, Dodd Frank, OTC, Paul Blank, Regulation, SEF, SWAPS | 1 Comment »
Posted on October 21, 2013 by Paul Blank
Last Friday, Javelin one of the 18 newly registered SEFs, become the first SEF to apply to the CFTC for determination of products to be Made Available to Trade.
This mean that the CFTC has up to 90 days to review the application, and make their determination. The application covers GBP, USD and EUR Interest Rate Swaps, and should it be approved, then these products would need to be traded on SEFs by all platforms.
In the 18 page application, Javelin notes that the CFTC recognizes that SEFs have:
“sufficient expertise and experience with respect to swaps trading to make an initial determination and to submit that determination to the Commission under the part 40 procedures.”
The Javelin application further states Continue reading →
Filed under: CCP, CFTC, Dodd Frank, OTC, Paul Blank, SEF, SWAPS | 2 Comments »