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White Papers

Chatham’s white papers provide in-depth analyses of key regulatory considerations. From the necessary components of regulation, to the impact of proposed legislation in the EU, these white papers offer a deeper, more technical look at specific issues that concern derivatives end users.


This white paper evaluates the merits of an unambiguous end-user exemption from margin requirements under Title VII of the Dodd-Frank Act, provides background on the public policy debate on margin, and evaluates the key criticisms of an end-user exemption from margin requirements.

Fed Tips Hand on Margin for Derivatives End Users (3/24/11)
Chatham Financial published this white paper in anticipation of the prudential regulators’ margin rule. It examines Congressional intent and the potential impact of end-user margin requirements on end users, the economy, and job creation.

Frequently Asked Questions About Derivatives and End Users (2/08/11)
Chatham Financial published this article in anticipation of the prudential regulators’ margin rule. The article examines Congressional intent and the potential impact of end-user margin requirements on end users, the economy, and job creation.

Top 10 Regulatory Risks for End Users in 2011 (12/29/10)
Chatham wrote this piece on the eve of 2011 to reflect on a landmark year in the history of finance and identify the top regulatory risks for derivatives end users.

AIFMD’s Passage and Its Implications On Derivatives Regulation (11/15/10)
This article summarizes the implications of the EU’s Alternative Investment Fund Managers Directive (AIFMD) on derivatives end users in Europe.

Summary of Key Issues from EU Derivatives Published Proposal (Sep 2010)
This article examines a draft proposal for derivatives legislation released by the European Commission on September 15, 2010, and summarizes the key issues for derivatives end users.

Summary of Key Issues from EU Derivatives Published Proposal (Sep 2010)
This article examines a draft proposal for derivatives legislation released by the European Commission on September 15, 2010, and summarizes the key issues for derivatives end users.

Overview of OTC Derivatives Legislation (Jul 2010)
This overview of Title VII of the Dodd-Frank Act serves as a quick reference guide to the derivatives title for market participants.

Overview of OTC Derivatives Legislation (Jul 2010)
This overview of Title VII of the Dodd-Frank Act serves as a quick reference guide to the derivatives title for market participants.

Evaluating SEFs as a Transparency Mechanism in the OTC Derivatives Market (2/2/10)
This article evaluates the merits of SEFs as a transparency mechanism and identifies some practical concerns with the SEF requirement.

Rebuttal of Hedge Fund Attack on End User Concerns of OTC Reforms (Oct 2009)
This is a point-by-point rebuttal by Chatham against a published document that attempts to persuade policymakers toward enacting legislation that would mandate central clearing for as many derivatives as possible.

Evaluating Margin Lending Facilities in the OTC Derivatives Market (Sep 2009)
This paper identifies and discusses the drawbacks to legislative proposals to legislative proposals that would create margin lending facilities to help address the problems associated with requiring end users to cash collateralize their trades.


In one of our early meetings with policy makers, they asked, “What would you do?” We responded with this proposal.

17 Reasons Why Clearing Should NOT Be Required for All OTC Derivatives (Jul 2009)
Prior to the passage of the Dodd-Frank Act, Chatham wrote this document offering 17 reasons for why clearing should not be required for all OTC derivatives.