Trading has now begun on Swap Execution Facilities but there remain numerous issues that must be clarified for these new trading facilities to function effectively, says Galen Stops.
The confusion prevalent amongst market participants regarding
the Sef rules, and in particular the now infamous "footnote
88", forced the CFTC to issue three no-action relief letters
delaying the implementation of some of the Sef rules for one
The irony of the fact that on such a day of significant change
for the derivatives industry the regulatory body was shutdown
has not been lost on Wall Street.
Footnote 88 effectively means that more financial institutions,
including those in different regulatory jurisdictions, will be
required to register as Sefs and that a much broader range of
products will be required to trade on these platforms than was
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