Article: CFTC causes ironic eTrading paper trail | Risk article13 February 2014 | Jon Skinner
Further to pushing eTrading offshore through footnote 88 of its SEF rules, another footnote (195) was clarified by CFTC to demand SEFs become a central source of paper ISDA master agreements for non-cleared products executed on their platforms - says a Risk article (subs. required).
It turns out from the January 30th CFTC public meeting that SEFs have to obtain and store a paper copy of the ISDA master agreement between each new pair of parties doing a non-cleared trade between them to be executed on their platform. Oh and we don't know whether the SEF falls out of compliance on SEF MAT date or is already out of compliance back to October 2nd when the first set of SEF rules for permitted transactions went live.