In the past I’ve spoken about buy side incentives for using an agency model – chief among them the reluctance or inability to navigate the slew of legal documents an institutional investor would need to sign in order to gain access to the needed...

The CFTC issued a slew of new guidance and rules last week, two of them particularly interesting and impactful. First was the rule that requires clearinghouses to have credit facilities available to back up all margin posted in US Treasuries. I (and...

Forgive me if I’m stating the obvious for some of you, but I’ve had this conversation more than once and felt some clarity was in order here. As we work through the made available to trade (MAT) process, it’s important to reemphasize what actually...

Last week was a busy week in SEF land. November 1 brought in to play a host of new rules, the MAT wars heat up and the Commission made the void rule even more confusing than it was car-flying-off-cliffbefore. So where has that left us? With a huge...

OK, so not all of it. On Friday at 5:55pm (which I guess is better than 11:59pm on October 31) the CFTC issues somewhat expected no-action relief for parts of the SEF rules set to take effect on Friday November 1. It focuses on the so-called Void...

Earlier this week the first two made available for trading applications were made to the CFTC starting the clock ticking for mandatory mat chartSEF trading. Those applications started a debate as to exactly how mandatory SEF trading should be phased...

On October 2 swap execution facilities (SEF) became official and started reporting trading volumes. While this new level of Greenwich Associates transparency is exciting, today’s reported volumes don’t really matter. In addition to the lack of...