In the US, the new market structure is largely complete, battle-lines have been drawn and we will soon see which firms gain and which firms lose. In many ways the baton of reform will pass from the US to Europe and Asia.

The European EMIR and MiFD Directives will come into force with the start of mandatory reporting in February 2014 and subsequent dates for mandatory clearing and trading on Organised Trading Facilities (OTFs).

Further afield, we see Trade Repositories and Clearing Houses, blooming all over Asia, with Tokyo, Singapore, Hong Kong and Australia, either already live or rolling ahead with implementation plans.

Of more importance than 2014, is the market structure not in 2014, but in 2018. One key characteristic is whether the swaps market will be horizontally integrated or vertically integrated like the futures markets. Despite the regulatory framework of open and competitive markets, so a product can be traded on one venue and then cleared on another, we now see in Futures a few large firms that are vertically integrated and national champions. CME, Eurex, ICE each trade and clear specific products in which they have all the liquidity.

Despite their privileged position, large profits and market capitalisation (CME $25 billion, ICE $23 billion), we do not see the same sort of press coverage as we get about Investment Banks and their out-size profits ($44 billion is an oft-quoted number).

While it is true that regulators did not find cause to implement significant reforms for Futures and Exchanges would say they are capable of efficiently processing massive volume, we cannot afford to be complacent.

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