In the wake of the Commodity Futures Trading Commission's establishment of Dodd-Frank Act-mandated swap-execution facilities, Asian firms are beginning to move their derivatives trading to London brokers, according to some analysts. "We were advised to trade our swaps on SEFs out of London because that is outside the jurisdiction of the Dodd-Frank rules. We are, therefore, already seeing some regulatory arbitrage and this has led to mass confusion in Asian banks with operations in the U.S.," said Frederick Shen of OCBC Bank in Singapore.

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