DOCSLIB.ORG

Frequently Asked Questions About Block Trade Reporting Requirements

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Frequently Asked Questions About Block Trade Reporting Requirements FREQUENTLY ASKED QUESTIONS ABOUT BLOCK TRADE REPORTING REQUIREMENTS smaller amounts of stock than are typically offered in an Block Trades and Distributions underwritten transaction. What is a block trade? When must a block trade be reported for FINRA Many people use the term “block trade” colloquially. purposes? Technically, a block trade is an order or trade submitted The execution of a block trade may vary. A block trade for the sale or purchase of a large quantity of securities. may be offered and sold in a manner that would render Although the term is not defined under the securities it a “distribution.” For purposes of the Financial laws, Rule 10b‐18 under the Securities Exchange Act of Industry Regulatory Authority, Inc. (“FINRA”) trade 1934, as amended (the “Exchange Act”), refers to a reporting rules, “distribution” has the meaning set forth “block” as a quantity of shares with a purchase price of under Regulation M (see definition below). A $200,000 or more or a quantity of shares of at least 5,000 “distribution” generally does not need to be reported with a purchase price of at least $50,000. Block trades under the trade reporting rules. However, a are typically executed by institutional investors “distribution” may be subject to reporting under (including mutual funds and pension funds), financial Regulation M. A FINRA member (“member”) must or private equity sponsors, venture capitalists and other notify FINRA when participating in any “trade” or large stockholders who may have acquired large “transaction” in an over‐the‐counter (“OTC”) equity quantities of securities in a merger, acquisition or other security that is not subject to an exemption under the transaction and wish to sell down their position. trade reporting rules. For purposes of the trade Block trades offer a number of advantages to selling reporting rules, a “trade” or “transaction” involves a shareholders. For instance, many securities exchanges change of beneficial ownership of securities between permit large block trades to be privately negotiated and parties (i.e., a purchase or sale of securities) in which a transacted off‐exchange. In addition, a block trade member participates (i.e., as an agent or a dealer). allows a party to access a different and often larger FINRA Rule 5190 requires members to provide investor base than regular electronic trading. Finally, information related to a “distribution” of securities block trades are often cheaper than standard subject to a restricted period under Regulation M, such underwritten transactions, and are fast and effective for as the determination of the restricted period under “distribution.” Similarly, the block repurchase Regulation M, whether members are relying on the limitations under Rule 10b‐18 under the Exchange Act “actively‐traded securities” exemption and pricing provides a safe harbor from liability for market information.1 manipulation when an issuer or its affiliated purchaser engages in a block repurchase of shares of the issuer’s Is there any helpful guidance under Regulation M for common stock. determining when a “distribution” exists? Regulation M was adopted by the Securities and Special selling efforts and selling methods Exchange Commission (the “SEC”) in order to curtail Activities that may constitute “special selling efforts and manipulative practices by distribution participants and selling methods” might include a broker‐dealer provides some guidance for determining whether a receiving higher compensation than it ordinarily would distribution exists. Under Regulation M, a receive for normal trading transactions or dealer “distribution” is defined as “an offering of securities, activity, using sales documents, conducting a road show whether or not subject to registration under the in connection with a transaction or holding investor Securities Act, that is distinguished from ordinary meetings. trading transactions by the magnitude of the offering The guidance under Regulation M is useful because it and the presence of special selling efforts and selling narrows the broad scope of the definition of an methods.” underwriter by limiting the situations in which that definition is implicated. The definition of a distribution Magnitude of the offering is based on facts and circumstances, and can lead to the In determining the “magnitude of the offering,” the SEC similarly structured transactions being considered a will look at the number of shares being sold, the distribution in one case but not in another. For this percentage that these shares represent of the total shares reason, a broker‐dealer must analyze each situation not outstanding of that issuer, the issuer’s public float and only on its merits, but also in the context of its regular the average trading volume of the issuer’s securities. activities. If a broker‐dealer is concerned about whether The SEC has provided guidance regarding trading its activities constitute a “distribution,” the broker‐ volume, as it relates to determining whether a dealer may find it prudent to conduct diligence transaction is deemed a “distribution.” For example, activities and enter into an agreement with its client, Rule 144 (“Rule 144”) under the Securities Act of 1933, providing for the making of representations and as amended (the “Securities Act”), imposes a volume warranties and requiring the delivery of opinions of limitation requirement which provides a safe harbor for counsel. sales of securities that would otherwise be deemed a What is a “distribution” in the context of a block trade? 1 FINRA members are required to submit these Regulation M Generally, trading activities for a block may not rise to notices electronically through FINRA’s “Firm Gateway” system. For more information regarding Regulation M, see our the level associated with a “distribution” under federal “Frequently Asked Questions About Regulation M” available at: http://media2.mofo/documents/faqs‐regulation‐m.pdf. securities laws. Shares that are purchased and sold in a Morrison & Foerster LLP 2 block trade are often placed quickly by an investment (pursuant to a registration statement) transaction. As bank’s block trade desk and executed for a standard used in the Securities Act, an “issuer” is defined to “dealers’ fee,” without the use of sales documents and include the issuer itself and its affiliates or control without special selling efforts. Further, these shares persons. In executing a block trade on behalf of an often are sold to relatively few institutional buyers who issuer or on behalf of an affiliate, a broker‐dealer should already may have expressed an interest in acquiring consider the factors discussed above and may wish to stock should a block become available. However, under structure its activities in a manner intended not to be a certain circumstances, block trades may be considered a “distribution.” However, if a broker‐dealer is executing “distribution,” which has the effect of exposing the a block trade on behalf of a third party (unrelated to the broker‐dealer to potential liability as a statutory issuer and not an affiliate or control person), depending underwriter. on the facts and circumstances, the transaction will Under Section 2(a)(11) of the Securities Act, an more likely than not be deemed to constitute a “underwriter” is defined as “any person who offers or “distribution.” sells for an issuer in connection with the distribution of This broad definition of a “distribution” is fact‐specific any security.” The SEC has defined “issuer” broadly to and the SEC has routinely refused to make include any person directly or indirectly controlling or determinations on specific cases, explaining that the controlled by the issuer or under common control with individual or entity in question is in a better position to the issuer. As a result, activities undertaken by a determine its status than the SEC. In addition, the broker‐dealer on behalf of affiliates of an issuer (officers, Securities Act does not contain definitions for certain of directors or greater than 10% stockholders) may raise the other terms used in Section 2(a)(11), including the the same concerns as those taken on behalf of the issuer. term “distribution.” It is clear that only when a Further, a broker‐dealer does not need to be engaged distribution occurs can an underwriter be involved. formally as an underwriter or placement agent in order to incur this potential liability. The broker‐dealer’s Reporting Requirements relationship to the transaction, the extent of its activities, and its fees, taken as a whole, will determine whether it What are the reporting requirements for block trades may be considered to be acting as a statutory under the exchanges? underwriter. In general, the transaction reporting requirements for The nature of the party for whom the broker‐dealer is the New York Stock Exchange (the “NYSE”) and executing the block trade also may implicate the NASDAQ are similar. The NYSE has a general broker‐dealer as a potential underwriter. A reporting rule specifying that transactions must be broker‐dealer will be considered a statutory reported promptly. In particular, NYSE Rule 131 underwriter if the broker‐dealer participates in a specifies that trades must be reported within an hour distribution of securities for an issuer. A “distribution” after the close of business on the day the trade was may include a private transaction as well as a public made. Morrison & Foerster LLP 3 The NASDAQ rules provide more detail as to the is closed are not subject to the 10‐second reporting types of information a broker‐dealer must provide for requirement. Specifically, trades executed between equity trades. A broker‐dealer must specify the midnight and 8:00 a.m. ET must be reported by following information: 8:15 a.m. ET on the trade date, and trades executed the symbol of the stock; between the close of the relevant reporting facility and midnight or on any non‐business day (i.e., holiday or the number of shares bought or sold; weekend) must be reported on an “as/of” basis by the price paid or received for such shares; 8:15 a.m.
Load more

Recommended publications
  • The Upstairs Market for Large-Block Transactions: Analysis and Measurement of Price Effects
    The Upstairs Market for Large-Block Transactions: Analysis and Measurement of Price Effects Donald B. Keim University of Pennsylvania Ananth Madhavan University of Southern California, Los Angeles This article develops a model of the upstairs market where order size, beliefs, and prices are determined endogenously. We test the model’s predictions using unique data for 5,625 equity trades during the period 1985 to 1992 that are known to be upstairs transactions and are iden- tified as either buyer or seller initiated. We find that price movements prior to the trade date are significantly positively related to trade size, con- sistent with information leakage as the block is “shopped” upstairs. Further, the temporary price impact or liquidity effect is a concave func- tion of order size, which may result from up- stairs intermediation. We thank Margaret Forster, Thomas George, Larry Glosten, Gary Gorton, Larry Harris, David Mauer, Oded Sarig, Byron Snider, Chester Spatt (the edi- tor), and an anonymous referee for their helpful comments. Seminar partic- ipants at Boston College, Columbia University, INSEAD, London Business School, Ohio State University, Temple University, University of Maryland, University of Southern California, University of Wisconsin, Washington Uni- versity, the 1991 Johnson Symposium, the American Finance Association Meetings, and the European Finance Association Meetings provided many useful suggestions. We also thank Dimensional Fund Advisors, Inc., for pro- viding us with the data used here, and the Q-Group and the Geewax-Terker Research Program at Wharton for their financial assistance. Edward Nelling and Pasi Hamalainen provided expert research assistance. Any errors are entirely our own.
    [Show full text]
  • Cross-Trading by ERISA Plan Managers
    Cross-Trading by ERISA Plan Managers Final Report Thomas H. McInish, Ph.D., C.F.A. Tel: 901-678-4662 Fax: 901-678-3006 Email: [email protected] Cross-Trading by ERISA Plan Managers Executive Summary ERISA prohibits cross trades, the exchange of assets between two accounts without going through a public market. There have been numerous exemption requests motivated by a desire to reduce transaction costs. Mutual funds are permitted to cross trade under Rule 17a-7. Opportunities for cross trades arise when some funds within a group have cash inflows and others have cash outflows and due to differences of opinion among managers for a given mutual fund group about the desirability of holding particular assets. Cross trades represent an economically significant source of savings for mutual funds. With a view toward identifying insights relevant to cross-trading, this study reviews the academic literature dealing with the way financial markets are organized and how this organization affects transaction costs, dealer quotes and prices, and other market characteristics. Transaction costs include direct costs such as commissions and indirect costs such as the bid-ask spread, which covers order processing costs (the normal expenses of providing liquidity) and asymmetric information costs (dealer losses to informed traders). Additional indirect costs are market impact costs, delay costs, and the opportunity costs of missing a trade. Transaction costs typically range from one to four percent, depending on a number of factors such as the type of asset (equities, debt, derivatives, and currencies), daily trading volume in the asset, the size of the order, market conditions (recent news, whether others are buying or selling), and the country in which the asset is traded.
    [Show full text]
  • MARKET RULES and Appendices ICE Endex Markets B.V. Atlas Arena
    MARKET RULES and appendices ICE Endex Markets B.V. Atlas Arena Amsterdam Australia Building, 3rd floor Hoogoorddreef 7 1101 BA Amsterdam The Netherlands Tel: +31 (0)20 305 5100 TABLE OF CONTENTS Preface - Introduction to the Rules 8 Chapter I. – General Rules 9 I-1 Definitions ........................................................................................................................... 9 I-2 Interpretation of the Rules ................................................................................................ 18 I-3 Structure of the Rules ....................................................................................................... 18 I-4 Objective of the Rules ....................................................................................................... 19 I-5 Requirements for Membership ......................................................................................... 19 I-6 Additional Membership Criteria for Direct Electronic Access Providers ........................... 23 I-7 Responsible Individual ...................................................................................................... 26 I-8 Application Procedure ....................................................................................................... 28 I-9 Obligations of Members .................................................................................................... 29 I-10 Obligations of Members engaging in Algorithmic Trading ................................................ 32 I-11 Rights of ICE
    [Show full text]
  • Block Trade Agreement for India Working Document, Version 1.0 Last Updated: 17 Nov 2015
    Asia Securities Industry & Financial Markets Association Block Trade Agreement for India Working Document, Version 1.0 Last Updated: 17 Nov 2015 www.asifma.org Follow ASIFMA on Twitter and LinkedIn Any person using the Template shall be deemed to have read, understood and agreed to the terms set out below: (i) This document Template (“Template”) is provided solely as a guide and is not intended to be, and must not be regarded or relied upon as, legal or other professional advice or opinions on any matters. Use of the Template is voluntary. You are advised to seek your own professional advice as necessary. (ii) All market participants signing block trade agreements are responsible for exercising their own independent judgment as to: (a) what information, and in what form, they should require the seller/manager to comply with their legal and regulatory obligations; (b) the sufficiency, accuracy, completeness and relevance of any information provided by any seller/manager; and (c) whether a particular agreement is appropriate under the particular circumstances and conditions applicable to them. (iii) For the avoidance of doubt, the fact that a seller/manager has submitted disclosures in accordance with the Template should not be regarded as an endorsement of that seller/manager by ASIFMA or an indication that the seller/manager is necessarily fit, proper or suitable for any particular user or purpose. ASIFMA accepts no responsibility for any information disclosed pursuant to or in accordance with this Template. (iv) Any description of legal or regulatory provisions in the Template is for informational and summary purposes only and is not intended to convey the full extent or details of regulatory obligations that may apply to any firm or individual.
    [Show full text]
  • Procedures to Establish Appropriate Minimum Block Sizes for Large Notional Off-Facility Swaps and Block Trades; Final Rule
    Vol. 78 Friday, No. 105 May 31, 2013 Part III Commodity Futures Trading Commission 17 CFR Part 43 Procedures To Establish Appropriate Minimum Block Sizes for Large Notional Off-Facility Swaps and Block Trades; Final Rule VerDate Mar<15>2010 18:49 May 30, 2013 Jkt 229001 PO 00000 Frm 00001 Fmt 4717 Sfmt 4717 E:\FR\FM\31MYR2.SGM 31MYR2 tkelley on DSK3SPTVN1PROD with RULES2 32866 Federal Register / Vol. 78, No. 105 / Friday, May 31, 2013 / Rules and Regulations COMMODITY FUTURES TRADING Off-Facility Swaps and Block Trades— 1. Policy Goals for Masking the Geographic COMMISSION Final Rules Detail for Swaps in the Other A. Criteria for Distinguishing Among Swap Commodity Asset Class 17 CFR Part 43 Categories in Each Asset Class 2. Proposed Amendments to § 43.4 1. Interest Rate and Credit Asset Classes 3. Application of Proposed § 43.4(d)(4)(iii) RIN 3038–AD08 a. Background and Proposed Appendix E to Part 43— b. Interest Rate Swap Categories Geographic Detail for Delivery or Pricing Procedures To Establish Appropriate i. Interest Rate Swap Data Summary Points Minimum Block Sizes for Large ii. Summary of Proposed Rule a. U.S. Delivery or Pricing Points Notional Off-Facility Swaps and Block c. Credit Swap Categories i. Natural Gas and Related Products i. Credit Swap Data Summary ii. Petroleum and Related Products Trades ii. Credit Swap Data Analysis iii. Electricity and Sources 2. Swap Category in the Equity Asset Class iv. All Remaining Other Commodities AGENCY: Commodity Futures Trading 3. Swap Categories in the FX Asset Class b. Non-U.S.
    [Show full text]
  • ICE FUTURES U.S. BLOCK TRADE – Faqs
    For More Information As of 3/13/08 Please Contact: Mark Fabian -or Jason Fusco V.P. Market Regulation Market Regulation Counsel (212)748-4010 (212) 748-4021 [email protected] [email protected] ICE FUTURES U.S. BLOCK TRADE – FAQs 1. What is a block trade?..........................................................................................1 2. How does a block transaction differ from an Exchange for Physical (“EFP”)/ Against Actual (“AA”) transaction?.....................................................................1 3. What are the eligible contracts and the minimum threshold quantities for a block trade?...................................................................................................................2 4. Who may participate in block trades? ..................................................................2 5. Are there any price restrictions for block trades?..................................................3 6. Can any order which exceeds the minimum quantity threshold be executed as a block trade? .........................................................................................................3 7. What are the trading hours for block trades? ........................................................3 8. What recordkeeping and audit trail requirements are attendant to a block trade? ..3 9. How are block trades reported?............................................................................3 10. What are the procedures for entering a block trade in ICEBlock?.........................4 11.
    [Show full text]
  • Frequently Asked Questions About Bought Deals and Block Trades
    FREQUENTLY ASKED QUE STIONS ABOUT BOUGHT DEALS A ND BLOCK TRADES offering and may be offered by the issuer (primary Bought Deals shares) and/or selling stockholder(s) (often affiliate(s)) What is a “bought deal”? of the issuer (secondary shares). The bought deal process will be substantially the same in either case. In a typical underwritten offering of securities, the underwriters will engage in a confidential (in the case of Given that the underwriters must agree to a price in a wall-crossed or pre-marketed offering) and/or a public advance of conducting any marketing, a bought deal marketing period (which may be quite abbreviated) to entails significant principal risk. As a result, build a “book” and price the offering of securities. In a underwriters in bought deals will negotiate a significant traditional underwritten offering, the underwriters will discount, to offset the risk when purchasing the have an opportunity to market the offering and obtain securities from the issuer or selling stockholder(s). indications of interest from investors before the Underwriters also may form a syndicate for a bought underwriters enter into the underwriting agreement deal so that each firm bears only a portion of the risk. with the issuer. What happens if the underwriters do not sell the By contrast, in a “bought deal” (sometimes also securities? referred to as an “overnight deal”), the issuer usually If the underwriters cannot sell the securities, they must will establish a competitive “bid” process and solicit hold them and sell them over time. This is usually the bids from multiple underwriters familiar with the issuer result of the market price of the securities falling below and its business.
    [Show full text]
  • Price Impact of Block Trades and Price Behavior Surrounding Block Trades in Indian Capital Market
    View metadata, citation and similar papers at core.ac.uk brought to you by CORE provided by Research Papers in Economics INDIAN INSTITUTE OF MANAGEMENT AHMEDABAD y INDIA Research and Publications Price Impact of Block Trades and Price Behavior Surrounding Block Trades in Indian Capital Market Sobhesh Kumar Agarwalla Ajay Pandey W.P. No. 2010-04-02 April 2010 The main objective of the working paper series of the IIMA is to help faculty members, research staff and doctoral students to speedily share their research findings with professional colleagues and test their research findings at the pre-publication stage. IIMA is committed to maintain academic freedom. The opinion(s), view(s) and conclusion(s) expressed in the working paper are those of the authors and not that of IIMA. INDIAN INSTITUTE OF MANAGEMENT AHMEDABAD-380 015 INDIA IIMA y INDIA Research and Publications Price Impact of Block Trades and Price Behavior Surrounding Block Trades in Indian Capital Market Sobhesh Kumar Agarwalla Ajay Pandey1 Abstract We analyze the permanent (information effect) and temporary (liquidity effect) impact of block trades transacted in the National Stock Exchange of India. Block trades are identified using multiple criteria based on trade value and trade volume. Overall, the permanent price impact is more for block purchases than for block sales indicating that block purchases are more informative than block sales, which may be motivated by liquidity need. Unlike in other markets, we observe that the temporary impact is greater than the permanent impact in case of block purchase. We classify the block trades as All-or-None (AON) and Not-AON trades depending on the number of transactions through which a block order is executed.
    [Show full text]
  • Responses to Frequently Asked Questions Concerning Rule 611 and Rule 610 of Regulation NMS
    Division of Market Regulation: Responses to Frequently Asked Questions Concerning Rule 611 and Rule 610 of Regulation NMS Responses to these frequently asked questions were prepared by and represent the views of the staff of the Division of Market Regulation (“Staff”). They are not rules, regulations, or statements of the Securities and Exchange Commission (“Commission”). Further, the Commission has neither approved nor disapproved of these interpretive answers. For Further Information Contact: Rule 611: Raymond Lombardo, Special Counsel, at (202) 551-5615; Rule 610: David Liu, Attorney, at (202) 551-5645; both of whom are in the Division of Market Regulation, Securities and Exchange Commission, 100 F Street, NE, Washington, DC 20549-6628. I. Introduction On April 6, 2005, the Commission adopted Regulation NMS, a series of initiatives designed to modernize and strengthen the national market system for equity securities. Regulation NMS was published in Securities Exchange Act Release No. 51808 (Jun. 9, 2005), 70 FR 37496 (Jun. 29, 2005) (“NMS Release”). These initiatives include: (1) Rule 610, which addresses access to markets; (2) Rule 611, which provides intermarket price priority for displayed and accessible quotations; (3) Rule 612, which establishes minimum pricing increments; and (4) amendments to the joint-industry plans and rules governing the dissemination of market data. This document jointly addresses Rule 611 and Rule 610 because the price priority and access issues arising under the two rules often are intertwined.1 The scheduled compliance dates for the phase-in of the two Rules are June 29, 2006 for 250 NMS stocks, and August 31, 2006 for all remaining NMS stocks.
    [Show full text]
  • Brief Overview of the World's Major Stock Markets and Their Trading
    A Survey of the World’s Top Stock Exchanges’ Trading Mechanisms And Suggestions to the Shanghai Stock Exchange Contents I. Introduction……………………………………………………………………………………1 II. Trading Mechanisms…………………………………………………………………………2 Types of orders……………………………………………………………………………2 Order precedence rules…………………………………………………………………..11 Market structures………………………………………………………………………...14 Order driven markets…………………………………………………………….15 Market makers/dealers, and specialists…………………………………………..18 Quote-driven markets…………………………………………………………….21 Brokered markets………………………………………………………………...23 Hybrid markets…………………………………………………………………...24 Block trading mechanisms……………………………………………………….25 Bond trading mechanisms………………………………………………………..28 Market information and order execution systems………………………………………..31 Trade pricing rules……………………………………………………………………….33 Trading halt rules………………………………………………………………………...35 Summary of the world’s top stock exchanges’ trading mechanisms…………………….36 III. Suppliers of Liquidity……………………………………………………………………...38 Dealers Block traders Value traders Arbitrageurs Buy-side traders Liquidity and orders IV. Recent Developments………………………………………………………………………43 V. Comments and Suggestions…………………………………………………………………51 More types of orders Market makers/dealers and institutional traders，OTC markets Dealer margin account, bank funds into stock market Block trading systems Short sales Elaborate call auctions Smaller minimum price increment More trading platforms Futures and options on T-bonds and stock indices A sign of the SEE? References……………………………………………………………………………………….57
    [Show full text]
  • On Liquidity Around Large-Block Trades: Upstairs Trading Mechanisms, Price Impacts and Common Factors
    On Liquidity around Large-Block Trades: Upstairs Trading Mechanisms, Price Impacts and Common Factors Chwen Chwen Chen Submitted for the degree of Ph.D. in Economics University of Lugano, Switzerland Accepted on the recommendation of Prof. G. Barone-Adesi, University of Lugano Prof. F. Degeorge, University of Lugano Prof. M. Murgia, University of Bolzano November 2004 To my parents, Pie’ and Tommino. 1 In ogni schema ordinato tendente a comporre il modello della vita umana `enecessario introdurre una certa dose di anarchia. Russell Bertrand, Scritti filosofici Tutto `equestione di misura. Anonimo 2 Acknowledgments Many people deserve my thanks for their part in creating this thesis. I am grateful to profes- sors of my committe for their comments and suggestions to improve my dissertation. I would like to thank professor Giovanni Barone-Adesi, my supervisor, for his encouragements and guidance through my PhD program. His humanity and his understanding of problems helped me to acquire alternative perspectives of doing research. I would like to thank professors Francoise Degeorge and Maurizio Murgia for their suggestions. I am especially grateful to professor Maurizio Murgia for providing helpful insights and vision that improved the quality of my work. I would also like to thank professor Aditya Kaul at the University of Alberta in Canada and professor Giulio Cifarelli at the University of Florence in Italy, who has been highly supportive over the years of my PhD program. My sincere thanks go to Simona Cain-Polli for her work as editor. She improved my English increasingly. Financial supports from the Gamma Foundation in Lugano in Switzerland, and Fon- dazione Cesifin “Alberto Predieri” in Florence in Italy, are gratefully acknowledged.
    [Show full text]
  • Block Trade Reporting for Over-The-Counter Derivatives Markets
    January 18, 2011 Block trade reporting for over-the-counter derivatives markets Contents Executive summary............................................................................................................. 1 1. Transparency and block trading.................................................................................... 3 1.1. Goals of transparency ...........................................................................................3 1.2. The cost of transparency – Illiquidity...................................................................3 1.3. Block trade exemptions ........................................................................................5 1.4. Considerations for implementation.......................................................................6 2. Transparency in securities and futures markets............................................................ 8 2.1. Trade reporting in the equity markets: the experience of the LSE .......................8 2.2. Trade reporting in the US futures markets............................................................9 2.3. Trade reporting in the corporate bond markets: the experience of TRACE.......11 3. The OTC derivatives markets ..................................................................................... 13 3.1. The rates markets................................................................................................15 3.1.1. Interest rate swaps ...................................................................................15 3.1.2. Other
    [Show full text]