Thursday, July 2nd, 2015 by GEORGE BOLLENBACHER For any investment firm operating a single‐dealer bond or swap ECN in Europe, MiFID II raises a life‐altering decision: whether to become an organized trading facility or a systematic internalizer. Here are some of the criteria firms must consider in making the OTF‐SI decision. For any investment firm operating a single-dealer bond or swap ECN in Europe, MiFID II raises a life-altering decision:… Read More »
Wednesday, May 13th, 2015 by GEORGE BOLLENBACHER As I have said in past articles, and since every swaps market participant and every swaps market regulator recognizes that transaction reporting has been something of a disaster, we are all waiting to see what the regulators will do about it. Recently, two swaps regulators went in somewhat different directions on this subject. The CFTC First, the CFTC issued two no-action letters (“NALs”)… Read More »
Thursday, April 30th, 2015 by GEORGE BOLLENBACHER The recent publication by the Volcker Alliance of a series of papers on reforming the financial regulatory structure makes interesting reading. You may or may not agree with their conclusions, but I, for one, can’t help but think that there are some important questions about structural reform lurking just under the surface, that were either not asked or were subsumed in these papers.… Read More »
Friday, March 20th, 2015 by GEORGE BOLLENBACHER In my last article I reviewed the SEC’s final and proposed rules on transaction reporting by market participants. In this article I will look at the final rule on SDRs, and make some observations on the effectiveness of current and future reporting regimes. The SEC’s final SDR rule is entitled “Security-Based Swap Data Repository Registration, Duties, and Core Principles” and runs some 468… Read More »
Tuesday, March 4th, 2015 by GEORGE BOLLENBACHER With all the discussion about Dodd-Frank, Volcker Rule, Basel III and EMIR, it’s easy to forget the last piece of the puzzle, Europe’s Markets in Financial Instruments Directive 2, Europe’s Markets in Financial Instruments Regulation, and Regulatory Technical Standards, hereafter known as MiFID II, MIFIR and the attendant RTSs. ESMA has been hard at work drafting all of these, and on February 19th… Read More »
Wednesday, February 19th, 2015 by GEORGE BOLLENBACHER In my last article I reviewed the SEC’s final and proposed rules on transaction reporting by market participants. In this article I will look at the final rule on SDRs, and make some observations on the effectiveness of current and future reporting regimes. The SEC’s final SDR rule is entitled “Security-Based Swap Data Repository Registration, Duties, and Core Principles” and runs some 468… Read More »
Wednesday, February 16th, 2015 by GEORGE BOLLENBACHER If you have read my previous articles on Tabb Forum, you will know that I believe the all-important swaps reporting requirement has been badly mishandled by the regulators worldwide, missing a golden opportunity to shed some light on this otherwise opaque market. In the US, one of the nagging problems has been that the SEC hadn’t put out its reporting rules, so there… Read More »
Wednesday, February 11th, 2015 by GEORGE BOLLENBACHER Recently I wrote about the debate in the US over risk management programs at CCPs, and how “skin in the game” was not a very comforting approach. A recent report by the European Commission on the use of CCPs by pension funds brings another aspect of this to light. First the report points out that, “Under EMIR, OTC derivatives that are standardised… Read More »
Friday, February 6th, 2015 by GEORGE BOLLENBACHER Given all the debate and discussion on the evolution of the swaps markets, including some negative comments by one of the new CFTC Commissioners, one group we have been waiting to hear from on this subject is the futures industry, where exchange trading and clearing have been working successfully for decades. Granted, swaps aren’t futures, but the Futures Industry Association’s (FIA’s) input is… Read More »
Wednesday, February 4th, 2015 by GEORGE BOLLENBACHER Last July marked the fourth anniversary of the passage and signing of the Dodd-Frank Act, so it is appropriate to reflect on the two sections of the DFA most of interest to OTC Space readers, Title VII on derivatives, and Section 619, the Volcker Rule. Title VII The first question we might ask about Title VII is whether swaps were really at the… Read More »
CMA is excited to welcome Diane Gabriel to our team as our Executive Director of Wealth Management Recruiting and Senior Business Development & Talent Acquisition Specialist.… Read More »
CMA is thrilled to announce that both David Carle of CMA and Nexus FrontierTech, as well as Danny Goh of Nexus will be speaking at… Read More »
The transition from LIBOR to the Fed-published Secured Overnight Financing Rate (SOFR) or possible alternatives is motivated in large part by the mandated cessation of… Read More »
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