Bank One Corporation - Page 189

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          floating rate in a foreign currency, or exchanging a floating               
          rate in a foreign currency for a floating rate in U.S. dollars.             
               E.  Participants in the Market                                         
               The main participants in the interest rate swaps market are            
          end users, dealers, and brokers.                                            
                    1.  End Users                                                     
                         a.  Typical End Users                                        
               End users are typically major corporations, government or              
          governmental-related entities, investment funds, or other                   
          financial institutions.  These end-users typically use interest             
          rate swaps to combat interest rate movements, express market                
          preferences through position taking, and/or reduce their cost of            
          funding.  As to the size of an end user, swaps end-user entities            
          entering into swaps in connection with the conduct of their                 
          business must have assets over $10 million or a net worth over $1           
          million in order to qualify their swaps for a safe-harbor                   
          exception from most of the regulatory requirements of the                   
          Commodity Futures Trading Commission (CFTC).15                              


          15 A swap must also meet three other requirements in order                  
          to qualify for such an exception.  First, the swap may not be               
          part of a fungible class of agreements which are standardized as            
          to their material economic terms.  Second, the creditworthiness             
          of any party having an actual or potential obligation under the             
          swap agreement must be a material consideration in entering into            
          or determining the terms of the swap agreement.  Third, the swap            
          agreement may not be entered into or traded on a physical or                
          electronic transaction execution facility in which participants             
          can simultaneously effect transactions and bind both parties.               




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