More co-operation needed to avoid footnote 88 fallout
More regulatory co-operation is needed to ensure footnote 88 doesn’t hurt liquidity inside and outside the US
Given the thousands of pages of in-depth rule-makings by the Commodity Futures Trading Commission (CFTC) over the past few years, it's perhaps surprising, and a little worrying, that a couple of last-minute footnotes, amounting to a handful of sentences in all, can bring certain parts of the market to a virtual halt.
These footnotes appear in the final swap execution facility (Sef) rules agreed by the CFTC on May 16, and an exemptive order related to interpretative guidance on the cross-border
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