Clarus Financial Technology

There is a new MAT Filing!

Made Available to Trade

Let’s do a poll to kick things off.

Before you clicked on this blog, did you know that there had been a new MAT filing?

I’m betting that most of our readers were well aware. The MAT filing, from Tradeweb, received decent press coverage, including from Risk:

https://www.risk.net/derivatives/7956487/tradeweb-lodges-mat-application-for-sofr-and-sonia-swaps

What Is It?

A MAT filing, or “Made Available to Trade” determination, is when a trading venue (SEF) submits a proposal to the CFTC stating that they deem certain swaps to be liquid enough to have an execution mandate applied to them.

Basically, a SEF says “I think these swaps should only be traded on SEFs in the future”. If you are captured by Dodd Frank, you then require an exemption to trade a “MAT’d” swap off-SEF.

MAT History

In most cases, MAT swaps are applicable to the interdealer market. They are the highly commoditised, standardised swaps that trade all day, every day between banks. The original MAT filing (October 2013), however, tried to cover everything! Anyone remember the particular kerfuffle over the original Javelin MAT filing? Tod provided a great insight into the teething problems in the early days of SEF trading:

For USD swaps, the final, accepted MAT filing covered the following:

Note these are all spot starting (or IMM) in major tenors. That means when we look at the history of MAT trading, these swaps don’t cover that much of total volume traded in USD swaps. The blue bars are MAT trades in the past five years:

As a sidenote, I think that means October 2023 will be the tenth anniversary of SEF trading. Wow!

Why Is It Required?

As we noted when looking at Clearing Mandates two years ago, there were no Clearing or Trading mandates active for SOFR swaps last year. You can see from the chart above that MAT swaps stopped trading in December 2021.

In October 2022, the CFTC finally introduced a clearing mandate for SOFR (and SONIA) swaps:

A MAT filing cannot be made until there is a Clearing Mandate in place, so this was a necessary “first step” to mandating (some) SOFR swaps to trade on SEFs.

What Has Happened to MAT Trading?

We obviously have a filter on our data to look only at MAT trades (because that’s what we do). Before LIBOR transition, MAT swaps accounted for 85-90% of all spot starting trades in USD swaps:

Showing;

What Currently Trades in SOFR

With no current MAT trading to analyse, we are essentially starting with a blank piece of paper. So what currently trades in SOFR? I covered this in detail back in March:

Stealing the most appropriate chart from that blog, we see the following for spot-starting SOFR swaps:

As I said at the time, the chart shows;

Astounding that nearly 20% of trades are in a single tenor.

And the new MAT filing is….

Likely surprising absolutely no one (particularly if you ticked “yes” to the poll question), the new MAT filing looks just like the old one!

Showing;

Good for Transparency

We find that the best quality data is still related to those swaps executed on-SEF. In addition, SEFs disclose the full size of their trades (albeit aggregated at a tenor level) within 24 hours of execution. Therefore, our gold standard for transparency, is a SEF-executed trade.

It is therefore very interesting to note what has happened to the overall share of USD swaps executed on-SEF in 2023. First, the percentage of trades executed on-SEF in the past 5 years:

Showing;

Drilling down to the past year:

Showing;

Which makes it seem even crazier to highlight that the proportion of the market traded on-SEF has decreased overall this year. It is an interesting one for sure…..

Finally…

The MAT process was reviewed in July 2015, with our very own Amir Khwaja asked to present a “Data-based Assessment of MAT” to the CFTC. It is well-worth revisiting, particularly as Clarus suggested some improvements to the public data:

It took nearly 8 years, but the changes to the public data were made in December 2022 and:

It is great that regulators listen and react to market participants feedback. It is crucial to help markets evolve.

In Summary

Stay informed with our FREE newsletter, subscribe here.

Exit mobile version