Save My Swaps - Reval Provides Education on the Regulatory Reform of OTC Derivatives

Welcome to SaveMySwaps.com

This site was created to provide the Obama administration as much feedback as possible on how to actually execute the regulatory reform of all OTC derivatives—a reform, outlined on June 17, 2009, that has dramatic and far reaching consequences. Right now, you have a small window of opportunity to shape that outcome.

It is clear that an overhaul of the OTC derivatives market is necessary, and increased transparency and reduction of counterparty credit risk will help to avoid future systemic failure. However, there are aspects of the reform that will add costs to plain vanilla end-users of derivatives who are hedging real interest rate, foreign exchange and commodity risks associated with their day-to-day businesses. Conservative corporations and financial institutions who, like many of you, were hedging and not speculating or creating leverage with OTC derivatives, will end up being penalized as a result of the pending reform.

Already the lobbying has begun by the various interest groups and associations trying to carve out certain types of derivative instruments that are defined as non-standard or “customized” OTC transactions, which would not be subject to margining or clearing via an exchange or central counterparty, but instead be subject to transparency and reporting through a regulated trade repository. Reval’s own unique proposal is to exempt FAS 133 effective hedges (see The Letter to Treasury Secretary Geithner).

Please take a moment to participate in the following survey, and we will share with you the results. Let your voice be heard!

1.	Should ALL OTC derivatives be regulated?	a. Yes b. No
2.	Would you support an effort to get FAS 133-effective hedges exempt from regulatory oversight?	a. Yes b. No
3.	How much would your company's use of OTC derivatives drop if posting margin became required?
4.	i. Do you use spreadsheets to manage derivatives?	a. Yes b. No, other:
	ii. If yes, do you think you can continue to use spreadsheets with the pending requirements for reporting and transparency?	a. Yes b. No
5.	What percent of your portfolio would you consider "standard" OTC derivatives vs "non-standard?"
6.	Under the proposed reform, non-standard OTC derivative contracts would not require clear/margining but would have to be reported on and regulated. How would this impact your use of non-standard derivatives?
7.	In your opinion, do you think the reform of OTC derivatives is necessary?	a. Yes b. No
8.	In your opinion, do you think the reform of OTC derivatives will succeed?	a. Yes b. No
9.	Please provide any additional comments.	Comments:
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	Comment to U.S. Department of the Treasury