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This, more than anywhere else, holds true for the financial markets, which are known to innovate to

keep pace with the growing needs and changing risk appetite of market participants. History of financial

markets is replete with examples of growth of markets giving rise to demands for new, different

instruments to enable investors to manage risks and markets innovating to satisfy these demands. As

an example, the innovation and growth of derivative instruments was the result of satisfaction of

demand of market players for a means to hedge price risk of holding an inventory of commodities.

While they first emerged as hedging devices against fluctuations in commodity prices and commodity-

linked derivatives and were the sole forms of such products for a long time, they were replicated for

financial instruments as well in the post-1970 period due to growing instability in the financial markets.

In the recent years, the market for financial derivatives has grown both in terms of variety of instrumentsavailable, their complexity and turnover.

As per the Futures Industry Association (FIA) Annual Volume Survey, more than 15 billion futures and

options contracts were traded during 2007 on the 54 exchanges that report to the FIA, an increase of

28% from the previous year. The growth rates were 19% in 2006, 12% in 2005, and 9% in 2004.

As regards the position of derivatives trading in India, among the top derivatives exchanges worldwide,

the National Stock Exchange of India (NSE) ranked 9th in 2007 in terms of futures and options volume

with 379 mn contracts being traded in 2007 (Source: FIA). In terms of trading volumes in single stock

futures, while the NSE was ranked first (1st) in terms on number of contracts traded in 2006, it has

shifted to second position as the Johannesburg Stock Exchange (JSE) overtook NSE with a 265.49

million contracts traded in 2007 at the JSE as against 179.33 contracts on the NSE11

.

The factors that have been driving the growth of financial derivatives worldwide are technological

developments leading to development of more sophisticated risk management tools; increased volatility

in asset prices in financial markets; increased integration of national financial markets with international

markets and the inherent characteristic of the derivatives markets to be able to optimally combine the

risks and returns over a large number of financial assets. These financial instruments are becoming an

increasingly important vehicle for unbundling risks as they enhance the ability to differentiate risk

and allocate it to those investors most able and willing to take it.

However, on their journey of innovation, derivatives have not been free from controversies. They have

often been held to be too complex to comprehend. The leverage that these products provide to investors

raises concern. Recently, the present global financial crisis is being attributed to the housing mortgages

being repackaged and sold as collateralised debt obligations and other exotic derivative products to

financial institutions, pension funds and individuals. Policy markers around the world are now having

ARTICLE

INDIAN DERIVATIVE MARKETS: SOME POLICY ISSUES

-Anuradha Guru10

"Necessity is the mother of invention" said the Greek philosopher, Plato.

10 The author is with the NSE. Views are personal.11Source: World Federation of Exchanges: Annual Report and statistics, 2007

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a relook as the problems being posed by derivatives viz. lack of homogeneous rules and accounting

standards; the excessive freedom allowed to market players to innovate and the lack of complete

statistics for exchange-traded and OTC transactions. Leaders are talking about the need for more

transparency and accountability in the functioning of derivative markets.

While this exercise is underway, the aim of this paper is to present the historical perspective in

which derivatives have developed in India and present certain issues which have been widely

debated in the context of these markets in India, while also presenting the international context

of the debates.

The regulatory framework for Indian derivative markets has evolved overtime starting with promulgation

of the Securities Laws (Amendment) Ordinance, 1995 which withdrew the prohibition on ‘options in

securities’ by repealing section 20 of the Securities Contracts (Regulation) at, 1956 [SC(R)A]. There

after, the Securities and Exchange Board of India (SEBI) appointed committee under the chairmanship

of Dr. L. C. Gupta in November 1996, which recommended an appropriate regulatory framework for

derivatives trading in India. In March 1998, the L. C. Gupta Committee (LCGC) submitted its report

recommending the introduction of derivatives markets in a phased manner beginning with the

introduction of index futures.

The Committee noted that:

"The evolution of markets in commodities and financial assets may be viewed as a worldwide long-term

historical process. In this process, the emergence of futures has been recognised in economic literature as

a financial development of considerable significance."

It further opined that:

"…financial futures have quickly spread to an increasing number of developed and developing countries.

They are recognized as the best and most cost-efficient way of meeting the felt need for risk-hedging in

certain types of commercial and financial operations. Countries not providing such globally accepted risk-

hedging facilities are disadvantaged in today's rapidly integrating global economy."

Thus, the decision to commence with derivatives trading was taken and another committee appointed

by SEBI in June 1998, under Prof. J.R. Varma, to recommend measures for risk containment for thesemarkets. Derivatives trading commenced in June 2000, after necessary legislative amendments12 and

SEBI approval, on the NSE and BSE. Trading first commenced in Index futures contracts in June

2000, followed by index options in June 2001, options in individual stocks in July 2001 and futures in

single stock derivatives in November 2001.

The LCGC was cautious in its approach towards launching of equity derivatives in India. It favored:

"… the introduction of equity derivatives in a phased manner so that the complex types are introduced

after the market participants have acquired some degree of comfort and familiarity with the simpler

types. This would be desirable from the regulatory angle too."

India's experience with derivative products has been very encouraging and we quickly emerged as one

of the most successful developing countries in terms of a vibrant market for exchange-traded derivatives.

The turnover in the derivatives segment of the NSE soon overtook the turnover in the capital markets

segment of the exchange. As per the latest data for the period April 08 to Nov 08, the turnover in the

12 The Securities Contracts (Regulations) Act, 1956 was suitably amended to define "derivatives" and classify them

as "securities" under the Act.

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derivatives trading. It released another draft guideline in May, 2007. Between March 2003 and

May 2007, four years have lapsed and the credit derivatives market has not yet started functioning.

Various apprehensions have been expressed about the preparedness of Indian markets for this product

in terms of risk management infrastructure and comprehension of the product itself. These

apprehensions of the market regulators have been aggravated further in the light of the present global

financial crisis as pointed out earlier in the article. Thus, this product has for the present been kept on

hold for the Indian markets.

Besides the issue of expanding the universe of derivative instruments available in the Indian markets,

two important policy issues that confront the markets are the choice between cash and physical

settlement and the choice between exchange traded and OTC derivative markets. These are elaborated

below

Cash vs Physical settlement

There has been much controversy about the two modes of settlement that are available for derivative

contracts, viz. cash and physical settlement, comparing the two on the basis of their vulnerability to

speculation and manipulation. Physical settlement, it is argued, provides the link to the real markets

of the underlying securities. However it is susceptible to distortions such as "short squeezes"13 . Cash

settlement, on the other hand, provides the benefits of avoiding the problem of delivery costs andlowering the effectiveness of market manipulations such as cornering and squeezing.

Presently, all derivative contracts in India are cash settled. Looking at the debate on cash vs physical

settlement of derivatives in India, we find that the LCGC Report took it for granted that physical

settlement would be used for derivative contracts on individual stocks. It noted that:

"In the case of individual stocks, the positions which remain outstanding on the expiration date will

have to be settled by physical delivery. This is an accepted principle everywhere. The futures and the

cash market prices have to converge on the expiration date. Since Index futures do not represent a

physically deliverable asset, they are cash settled all over the world on the premise that the index value

is derived from the cash market. This, of course, implies that the cash market is functioning in

a reasonably sound manner and the index values based on it can be safely accepted as the

settlement price.

However, when single stock derivatives were introduced in India, it was decided to use cash settlement

to begin with because the exchanges did not then have the software, legal framework and administrative

infrastructure for physical settlement. It was proposed that cash settlement would be replaced by

physical settlement as the exchanges developed the capabilities to achieve physical settlement efficiently.

In April 2002, SEBI's Advisory Committee on Derivatives (ACD) proposed a broad framework for physical

settlement presenting the risks and benefits of physical settlements along with possible risk containment

measures. The ACD noted the following as the principal issues involved in physical settlement:

• In the absence of a vibrant mechanism for securities lending and borrowing, physical settlementof stock specific derivative contracts, especially stock options, may raise concerns on the

possibility of a short squeeze.

13A situation where some economic agents adopt a long position on the futures market which is larger than the

stock of physical deliverable in existence, causing the spot price to rise and giving profits to the manipulator.

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• Globally, cash settlement is cheaper than physical settlement, but the economics may be

less clear cut in India where the modernization of the payment system has lagged that of the

securities settlement system.

• Under the existing procedure of cash settlement, hedgers and arbitrageurs incur overnight

price risk for liquidating one leg of the transaction in the cash markets. A hedger (who by

definition has a position in the underlying) would have to liquidate that position in the cash

market and then bears the risk that the price realized in the cash market would differ fromthe settlement price used for cash settlement in the derivative markets. The same argument

applies to arbitrageurs. Speculators on the other hand would find cash settlement beneficial

since they do not (by definition) have an offsetting cash market position and cash settlement

saves them the burden of operating in two markets. Physical settlement of derivative contract

helps hedgers and arbitragers avoid basis risk while imposing some additional costs on

speculators.

The committee held the view that the regulatory regime should be more in tune with the requirements

of hedgers and arbitrageurs than the needs of speculators. For this reason, it recommended physical

settlement which protects hedgers and arbitrageurs from basis risk in the settlement process. At the

same time, the Committee recognized the concerns regarding short squeezes in physical settlementand recommended certain measures to reduce the risk of short squeeze. As regards the mechanism of

physical settlement the Committee recommended a model where the cash market clearing corporation

is used to settle derivatives and the mechanism of physical settlement is such that at no point in time

are trades on the derivative segment commingled with trades on cash market.

SEBI approved of this recommendation and was of the view that it would be desirable to have a vibrant

system of margin-trading and securities lending and borrowing in the cash market, before allowing

physical settlement. Both the schemes were permitted by SEBI in March, 2004. The margin-trading

scheme was not successful as the market did not perceive the scheme to be attractive or efficient. The

ACD again deliberated on this issue and reiterated that physical settlement is dependent on a vibrant

securities lending and borrowing mechanism.

It is being debated that since a full-fledged securities and lending mechanism is now in place and short

selling by all market participants has been permitted (since April 21, 2008), it may now also be the time

to move to physical settlement of derivative contracts.

In this context, it would be instructive to ask if the physical settlement is an end in itself or a means to

something. If the objective is the efficient and liquid market where futures price converges with the

spot price on expiration, then cash settlement is equally effective, if not more. We look at some evidence

on the process of price discovery and market manipulation under the physical and cash settlement

system.

An "efficient" price discovery process happens when the private information embodied in the futuremarket participants seamlessly percolates to the spot market. Presented here are certain empirical

studies on efficiency of cash vis-à-vis physically settled derivative contracts. While the first two studies

deal with commodity markets, the implications would be even more pertinent in markets with financial

underlyings.

-Nabil Chaherli and Robert Hauser (1995) analyze the delivery system in the Chicago Board of Trade

corn and soybean contracts, alternative physical delivery systems, and cash settlement systems.

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A theoretical model of futures pricing with delivery option is used to simulate futures prices with

different terms of construct cash indices. Results suggest that cash settlement provides slightly higher

levels of hedging effectiveness than any type of multiple physical deliveries.

- Donald Lien and Yiu Kuen Tse (2002) investigate the effects of the switch from physical delivery to

cash settlement on the behavior of the cash and futures prices of the feeder cattle contract traded on

the Chicago Mercantile Exchange. The results show the following:

• Volatility of the futures prices (but not the cash prices) declined after physical delivery was

replaced by cash settlement.

• In terms of futures hedging, cash settlement led to smaller and more stable hedge ratios.

• The variance of the hedged portfolio also decreased substantially.

The evidence suggests that cash settlement is beneficial to the feeder cattle futures market.

- Donald Lien and Li Yang (2004) look at the experience of Australian stock exchange with the introduction

of physical delivery. The study investigates the effects of the settlement method change on Australian

individual stock and its futures markets. Specifically, it examines whether return and volatility of each

market, correlation between the two markets, basis behavior, and hedging performance of futuresmarkets differ across cash settlement period and physical delivery period. The study concludes that

after the switch from cash settlement to physical delivery, the futures market, the spot market, and

the basis all become more volatile.

In conclusion, there is, thus, no fundamental difference on price discovery and it is always possible to

obtain convergence of futures price to the spot price on expiration date, both under physical as well as

cash settlement, because this convergence depends upon arbitrage and it is perfectly feasible to do

arbitrage under cash settlement.

Prof Varma points out that according to Finance theory, the only difference between receiving the

underlying and receiving its price (i.e physical and cash settlement) is the transaction cost involved.14

To convert the price into the underlying or the other way around requires one transaction in the cash

market - nothing more and nothing less. Even these costs do not apply to most trades because they are

squared off before expiry. The choice of settlement mode can, according to him, therefore, be safely left

to market forces. But if the regulator chooses to intervene, it should be on the side of physical settlement

because it imposes lower transaction costs on hedgers and arbitrageurs at the cost of higher transaction

costs on speculators.

OTC vs exchange traded derivatives

Derivatives trading can be organized in two ways. The first way is through bi-lateral agreement between

counterparties, called the `over the counter' or `OTC derivatives' transactions. Another way is through

the anonymous order matching platform of the stock exchange. Exchange-traded contracts are

standardized, with regard to maturity date, contract size and delivery terms, whereas OTC contracts

are custom-tailored to the client's needs. Worldwide there is has been a phenomenal increase in OTC

transactions, as indicated from the table below:

14http://www.iimahd.ernet.in/~jrvarma/papers/BS-19Jan2004.pdf

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Global Exchange traded derivatives volume by category

(in USD millions)

GLOBAL 2007 2006 Percentage change

Equity Indices 5616.82 4453.95 26.1

Interest Rate 3740.88 3193.44 17.14

Individual Equities 4091.92 2876.49 42.25

Energies 496.41 385.97 28.61

Agricultural 645.64 489.03 32.02Metals 256.07 218.68 17.09

Currency 334.71 240.05 39.43

Others 4.23 4.36 -2.98

Total Volume 15186.67 11862.21 28.03

Source: Futures Industry Magazine, March/April 2008.

The growth in this market has been led by the innovations happening in structured finance and other

customized derivatives products. These innovations are driven by the investor's demands and the

competition among the institutional brokers to cater to these demands.

Some of the advantages of OTC contracts are:

• Buyers and Sellers can negotiate the contracts as per their respective needs to come with

customized products.

• Transaction costs can be reduced. The fees like exchange fees, clearing fees can be eliminated.

• OTC derivatives market can be used for executing bulk orders without the risk of market

impact.

Table below presents the derivative transactions on organized exchanges vis-à-vis those happening in

the OTC markets. As is evident from the data, while both exchange traded and OTC derivative

transactions are increasing, the rate of growth of amounts outstanding of exchange traded derivative

instruments was 14% over Dec-06 to Dec-07 vis-à-vis 43.5% growth in OTC derivations over the same

period. Over the period Dec-07 to June-08, the rate of growth of outstanding OTC derivative transactions

was 15% as against 5% growth in amounts outstanding on exchange traded derivative transactions.Products Dec-06 Dec-07 Jun-08

Derivative financial Interest rate futures 24,476 26,770 26,874

instruments traded on Currency futures 161 159 176

organised exchanges Equity Index futures 1,045 1,132 1,584

(amounts outstanding) Interest rate options 38,116 44,282 46,905

Currency options 79 133 191

Equity Index options 5,529 6,625 7,088

Total 69,406 79,101 82,818

Notional amounts of Foreign exchange contracts 40,271 56,238 62,983

OTC derivatives Interest rate contracts 2,91,582 3,93,138 4,58,304outstanding Equity linked contracts 7,488 8,469 10,177

Commodity contracts 7,115 8,455 13,229

Credit default swaps 28,650 57,894 57,325

others 39,740 71,146 81,708

Total 4,14,846 5,95,340 6,83,726

Source: BIS Quarterly review, December, 2008.

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Though OTC transactions have certain benefits as mentioned above, they are generally held to be faced

with problems of inefficient price discovery and large counterparty risk as they are privately negotiated,

devoid of novation which a clearing corporation offers. A recent IMF working paper15attempts to quantify

counterparty risk that may stem from the OTC derivatives markets. The risk is measured by losses

that may result via the OTC derivative contracts to the financial system from the default (or fail) of one

or more banks or broker dealers. It finds that considering that the notional value of all categories of the

OTC contracts reached almost $600 trillion at the end of December 2007, the failure of a single major

financial institution could result in losses to the OTC derivatives market of $300-$400 billion. Thepaper argues that since such a failure would likely cause cascading failures of other institutions, the

total global financial system losses could exceed $1,500 billion.

However, there is another aspect of this debate which argues that we are presently witnessing an

increasingly diminishing boundaries between the exchange traded and OTC derivatives markets. We

note the following:

a. Exchange-traded contracts are generally thought of as having been standardized (with regard

to maturity date, contract size and delivery terms), whereas OTC contracts are custom-

tailored to the client's needs. Some exchanges, however, have introduced derivative instruments

that can provide a significant degree of customization16. A notable example is the "Flex"

option, which was introduced by the Chicago Board of Options Exchange (CBOE) in February1993. Flex options allow investors to choose strike prices, expiration date and style. The

Chicago Board of Trade (CBOT) has introduced "Flexible Treasury Option" written on U.S.

Treasury bonds and bills which allows for investors' choice of exercise price, expiration date

and style. Such products are now also being offered by the Toronto Stock Exchange, the

Philadelphia Stock Exchange, the American Stock Exchange and the London International

Financial Futures Exchange etc.

Also, in practice, OTC markets may follow certain simplifying market conventions that provide a certain

degree of standardization. For example, most interest rate swaps in Canada are fairly standardized,

typically involving the exchange of cash flows on a contract's notional value based on 1-month or

3-month bankers' acceptances (floating interest rate) for 2- to 5-year Government of Canada bonds(fixed rate).

b. The general perception about OTC markets is that they have high counterparty risk. However,

the Bank for International Settlement's Committee on Payment and Settlement Systems

(CPSS), in a report on "New developments in clearing and settlement arrangements for OTC

derivatives", published in March 2007, based on a survey of 35 large OTC dealers, has inter-

alia, noted the following:

i. Expanded use of collateral now significantly mitigates counterparty credit risks, and the

legal and operational risks associated with reliance on collateral have been reduced by

changes in national law and enhancements to dealers' collateral management systems.

ii. The use of Central Counterparties (CCPs) has expanded in financial markets generally,spurred by increasing use of electronic trading systems. Some CCPs have also developed

15IMF Working Paper: Counterparty Risk in the Over-The-Counter Derivatives Market by Miguel A. Segoviano and

Manmohan Singh, November 2008.16 The Microstructure of Financial Derivatives Markets: Exchange-Traded versus Over-the-Counter by Brenda

González-Hermosillo, Bank of Canada (March 1994)

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services that enable products traded over the counter to be submitted for clearing. In

most instances, the OTC products are converted into equivalent exchange-traded

contracts to facilitate clearing and to allow for offsetting with exchange-traded products.

Examples include:

- Bclear, an exchange service launched by EuroNext.Liffe at the end of 2005, which brings equity

derivatives transactions initially conducted OTC to LCH.Clearnet for trade confirmation, administration

and clearing. The original transaction is replaced by an exchange contract through novation;

- the OTC Trade Entry Facility provided by Eurex Clearing AG;

- Clearing 360, a similar service offered by the Chicago Mercantile Exchange (CME) for OTC interest

rate derivatives. In operation since April 2006, Clearing 360 takes a bilaterally negotiated OTC swap

trade and converts it into a strip of futures contracts, which are then submitted to CME for clearing;

- Converge, a service launched in October 2006 by the Canadian Derivatives Clearing Corporation, a

wholly owned subsidiary of the Montreal Exchange. This service clears OTC equity options; and

- the New York Mercantile Exchange's ClearPort facility, which transforms OTC natural gas and other

energy derivatives into exchange-traded and cleared futures.

c. A trade information warehouse has been created by the Depository Trust & ClearingCorporation (DTCC) and launched in November 2006. The Trade Information Warehouse

("Warehouse"), as the market's central registry and industry-recognized post-confirm

infrastructure for credit derivatives, is optimally equipped to support any and all CCPs that

are established in the CDS market. Virtually all dealers and buy-side participants along with

15 third-party service providers in the global CDS market are already linked to the Warehouse

and utilize its functionality.

The position in India

Economic entities in India currently have a menu of OTC products. In respect of forex derivatives

involving rupee, residents have access to foreign exchange forward contracts, foreign currency-rupee

swap instruments and currency options - both cross currency as well as foreign currency-rupee. Forderivatives involving only foreign currency, a range of products such as IRS, FRAs, option are allowed.

The rupee interest rate derivatives presently permissible are Forward Rate Agreements (FRA), Interest

Rate Swaps (IRS) and Interest Rate Futures (IRF). Table below indicates the activity in the OTC markets

in India:

OTC derivatives turnover in April 2007

Daily averages, in mn of USD

OTC foreign Outward forwards 6,299

exchange Foreign exchange swaps 13,437

derivatives Currency swaps 479

Options 3,800

OTC single currency Forward rate agreements …

interest rate derivatives Swaps 3,395

Options …

Total 27,410

Source: BIS Triennial Central Bank Survey of foreign exchange and derivatives markets activity, 2007.

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17Converted at the 2007 calendar year annual average exchange rate, published by the RBI, of IUSD=Rs. 41.29.18http://www.iimahd.ernet.in/~jrvarma/papers/OTC-Derivatives-Bus-Std-online-14 Nov. 07.pdf

The corresponding activity on the derivatives segment of the largest derivatives exchange, the National

Stock exchange, in the month of April 2007 was Rs 30,8143 mn (or USD 7463 mn 17) of average daily

turnover.

Thus, in line with international trend, the OTC derivatives markets in India are far larger than the

exchange traded market for derivatives.

The debate on choice between the two ways of trading in derivative, viz. on exchange and OTC, in India

is on the same lines as the international debate. It is recognized that OTC trading, while permitting

unlimited flexibility in the contract, suffers from non-transparency, inefficient price discovery and

generally involves counterparty risk. However, there are some benefits of OTC markets, as pointed out

by Prof J.R.Varma, who argues for the creation of an OTC equity derivative market in India 18. He is of

the view that competition between OTC markets and exchanges forces each market to lower costs and

to adopt the best practices of the other market. He further holds that standardized and highly liquid

contracts are best traded in organized exchanges because of the enhanced transparency and lower

systemic risk. However new contracts are often best incubated in OTC markets until they achieve a

critical mass of liquidity and widespread participation at which point they can be moved to the exchange

traded format. Long dated equity options are today best incubated in OTC markets.

On the other hand, on the role of exchange-traded vs OTC derivatives, the recent report of Government

appointed High Powered Expert Committee on Making Mumbai an International Financial Centre has

stressed on a greater role for exchange-traded derivatives in an Indian International Financial Center,

inter-alia, for the following reasons:

- The present OTC market in India largely trades plain vanilla products for which exchange

traded platform is a better option as it provides transparency and liquidity at no cost in

flexibility.

- In an environment where India's regulatory and supervisory capacity in the derivatives markets

in still nascent but evolving, exchange traded markets are easier to regulate than the opaque

OTC markets which make greater demand upon regulation and governance.

- Exchange traded markets fit better with non-institutional customers who are not able to

access the telephone network through which OTC trading takes place.

- Exchange traded derivatives trading plays to India's strengths in running exchange institutions.

Our two national exchanges (BSE and NSE) and clearing corporations (NSCCL and CCIL) are

a strong set of institutions who can compete in the global market for exchange traded

derivatives.

The report, on this issue, concludes that India needs both exchange traded derivatives and OTC

derivatives. However, based on the above arguments, it is desirable to lay special focus on obtaining

world-class liquidity on the exchange platform, after which OTC market can spring up based on utilizationof the prices and liquidity produced on this platform.

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In conclusion, one has seen a significant growth of OTC derivatives market world over. Internationally,

the problems of technology solutions and risk management are increasingly being addressed by new

developments in the market like introduction of electronic trading and confirmation systems, CCP

clearing the trades etc. With these developments happening, analysts have argued that it is actually

leading to unification of the organized exchange market and the OTC market. There are other sets of

analysts who feel both the exchange and OTC derivatives market will co-exist as they cater to needs of

different user.

However, there is a renewed debate on the level of transparency and counterparty risk in the OTC

markets kindled by the sub prime mortgage crisis in the US and the need to regulate OTC transactions

effectively, as also mentioned in the introduction of this article. This throws up important issues

which, at best, may need to be handled separately.

For the present, one could say that these markets, viz. exchange traded and OTC, are two competing

market and each have unique characteristics.

References

Nabil Chaherli and Robert Hauser, “Delivery Systems versus Cash Settlement in Corn and Soybean

Futures Contracts,” SSRN working paper. February 1995.

Donald Lien and Yiu Kuen Tse, “Physical delivery versus cash settlement: an empirical study on the

feeder cattle contract,” Journal of Empirical Finance, November 2002.

Donald Lien and Li Yang, “Alternative settlement methods and Australian individual share futures

contracts,” Journal of International Financial Markets, Institutions and Money December 2004.

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