In-depth introduction: Sefs/OTFs

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Lawyers really know how to complain. There’s something coldly surgical about the language they deploy – wielding adjectives like scalpels, listing grievances with exhaustive, deliberate skill. As an example, take the letter sent to the Commodity Futures Trading Commission on behalf of Bloomberg on March 11 – the complaint is that the agency’s rule on minimum margin requirements for over-the-counter swaps hands an unfair advantage to futures, benefiting derivatives exchanges at the cost of would-

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