For group swap orders, two clearing execution streams are available, either before or after trading. An asset manager`s preference may depend on a number of factors that take into account the manager`s business practices, investment authority and fund structure. When a post-trade allocation model is used, the asset manager must enter into a stand-by agreement to guarantee the bundled exchange contract at the time of the SEF. As a general rule, this agreement stipulates that the FCM removes the bundled contract on the basis of a credit limit applied at the asset manager level and then assigns the contract to individual funds after execution, on the instruction of the asset manager. In the context of the upcoming Dodd-Frank trading request, which will require market participants to trade on an exchange facility (“SEF”), many futures commission traders (“FCMs”) now accurately accept how clients trade in clear swaps such as interest rates and credit risk swaps. For asset managers, there are currently three delivery models: We know that we are focusing on this, but we strongly advise, particularly our non-U.S.-based clients, whether they can be considered a U.S. person or whether they may be subject to the commercial requirements of the SEF in another capacity. . To distinguish trades on and off the SEF, all SEF-related items (platform functions, entity names, products, etc.) are displayed in green in the user interface and “SEF” in high characters.
In order to offer these services, NFA requires that each DCM or SEF have a standardized RSA with NFA. Note: Companies above established companies are companies that had significant swap activity prior to comprehensive regulatory reform. The following list is based on newcomers (created under the Dodd-Frank Act) and less well-established participants. As such, this section will necessarily be more illustrative than completely current and probably a little temporary. . Many of the above entities, directly or through related companies, have current OR temporarily approved SEF registrations with the CFTC.  Temporary-registered FSEs can last up to two years, while the CFTC conducts a full review of the SEF application on the SEF form.