Unpacking the Agenda with Scott O’Malia

'Hello everyone, and welcome to another episode of LSEG Post-trade Solutions, Ahead of the Curve. I am John Pucciarelli. I will be your host today. With me today is Scott O'Malia, CEO of ISDA, again. Scott, welcome back to the podcast. How are you? Very good. Thanks for having me. -Great. This is our fourth time together. I think you're in the category of regular now. There you go. -Thank you so much for joining us today. We have a lot to talk about. Usually, when we get together, we dub this podcast, you and I, unpacking the agenda. The reason why we say that is obvious, there is always a ton to talk about. We're going to get into that in a second, but before we do that, as we're recording this podcast, we're in the throes of summer. We're just at the doorstep of it. Half a year is already done. We've had the AGM, which we're going to talk about in a second, but so far, what's going on? How's your year so far? How's everything going generally for ISDA and for yourself personally, et cetera? -It's good. It's got busy. It's been very busy. We started right out of the blocks in January. We had events in Saudi Arabia. We are meding legislation there now, and legal opinions are coming through. That was in March. We were flying through the year. Where we have gotten this far is a lot of work that has already been done. We've been working with the new Trump administration. There's a lot of change going on still in Europe with their regulatory reforms. There's a lot of implementation. We've been to India. We've been all over Asia to support innovation and the use of derivatives in a safe and efficient manner. -Great, it's funny. You mentioned the Trump administration. Obviously, we have a new Trump administration. It came in January. I think one of the podcasts that we did in the past, we were talking about the new Biden administration, talking about it even when Gary Gensler was becoming the SEC chair. That's how long it's been for us, and we've seen the evolution of things happening. We'll talk a little bit about geopolitical stuff in a minute, and changes at the agencies as well, but before we do that, we had another AGM. This was the 39th AGM. I get confused a little bit because I know we're celebrating the 40th anniversary of ISDA, which we'll talk about later. This is the 39th AGM in Amsterdam. Another great event. A lot to talk about. What are some of the things from your very unique perspective as CEO of ISDA? What are some of the things that stood out to you? It could have been the content. It could have been Amsterdam. I'm always curious to hear your take on it. I know lot of work goes into it as well. -It's an enormous amount of work, but it was a successful AGM. Great attendance, wonderful city. Amsterdam's such a great city. A lot of people came in before and stayed longer to enjoy that. We had great weather at the time, so it was perfect. The content was excellent. There was a lot of discussion around geopolitical changes and what's going on. We also talked a lot about the implementation of the work that we're doing. Obviously, Basel is a big issue that we were very focused on. US Treasury clearing. The clearing mandate is a huge issue, and we'll walk through some of the things later in this podcast. I suspect that we'll get to that issue. Also, emerging markets. Talking about how ISDA is constantly thinking about how we make safe and efficient markets all over the world. I mentioned Saudi Arabia and India as two of the big targets for us. We've had a very successful engagement there. We'll continue on that bit of work. The other bit was the 40th anniversary, as you mentioned. We had that Covid year, so actually, in 2020 we did not have an AGM. That's why the math doesn't work, but yes, it is the 40th anniversary, and we were able to celebrate that. We brought back some of them. Not brought them back, they've been part of the ecosystem for all of these years, but we had a great panel about the history of ISDA and all the way back to the very origins and beginning. That was a fascinating conversation and discussion. I think a lot of people who came back may not have been back recently. We were really able to share some of their perspectives. It's amazing that it went from just a small niche kind of financial services opportunity to what we have today, which is a global, super important risk. -Trillions of dollars and notional. I'm a history buff on a lot of things. I love history, and this is no different for me. Obviously, it's close and near and dear to both of our hearts. Just to see that and to mark the time, and seeing the folks that were there in the beginning was great for me, too. To see where it's all come. I think it's important for other people, especially newer folks coming into the derivatives market, learning about ISDA for the first time, it's really important to let them know where it all started. I think it's great. We're going to talk about future leaders, too. We have a lot to talk about in that program, as well. One of the other things that came out of the AGM was SIM. SIM 2.7. Twenty-four, 12. -Yes, 24. Version 24.12. -Just to give people a perspective on that. Obviously, from an LSEG Post-trade Solutions perspective, it's core to our business. We have an initial margin exposure manager where we are the standard for reconciling sensitivity. We're always working directly with you guys, with your staff, to make sure that we're on top of things, we pass the unit tests, et cetera. I want to talk about it with you because it's something new and different. There's some semi-annual recalibration that's happening now, and there's also something going on in the EU as far as the approval process, and they're going to put out some really great information. It's all free on the website to help firms deal with that. Do you want to just give us a little bit of background on that? What is your perspective on that as well? -Sure. As you noted, we're in 2.7-2412. It's our first biannual recalibration. This is what we've worked with the regulators over 2024 to implement and get to the spot. We will do a recalibration twice this year to support and make sure that SIM is fit for purpose in the environment and is used all over the world. It has become a great solution that both regulators and the market can benefit from because it has regulatory oversight and approval. In all of the jurisdictions where it's provided, people have a way to responsibly and appropriately regulate and get their arms around this thing and work through this. We've added a couple of new jurisdictions this year. We're working towards China. We're working towards India. They have rules drafted today, South Africa, Mexico, or the new ones coming through. We have to continue to support all of the jurisdictions that have it today, as well as expand it and make it relevant going forward. You mentioned the role that we play versus the role that you play. It's super important. We can set the standard and then hand it off for industry implementation. The fact that you are out there supporting your customers to provide this service is fantastic. Our job is to make it current, relevant, and regulatory-approved, save everybody the hassle of doing it themselves. In all the jurisdictions, I think today we're over 12 jurisdictions, and we make their job a lot easier. -It's something new. Anytime there's something different, everybody's like: "How are we going to deal with this?" -You mentioned the European. Yes. -There's a requirement that you have to get your model approved in the jurisdiction where you're using it in Europe, and that's right. That's true. There's a deadline of July 12th, and we're coming up against that. It's a notice to the regulator. If you're a significant entity, you have to know the ECB as well. The larger banks. -Yes, exactly, but just to make sure that you file your notice with it, you can find the rest of the material on our website. What you have to do and to whom you have to do it, and that's the best pathway forward. I don't think that they're particularly doing anything with the material yet, but they will be going forward. Yes, I think, there were a lot of questions from my perspective on the LSEG side, clients asking: "What do we have to do?" We were giving our perspective and working closely with ISDA on what the requirements are because we have the EBA being like the central approval, but that's kind of down the road a little bit, and it was like, do we go to the EBA? What do we have to do? ISDA came out in a very timely fashion with "This is what you're supposed to do." Meaning firms, not the larger banks, but all the other smaller entities, go to their competent authorities. Correct. -That was great because it wasn't clear. The regulators that made it clear were those who came in and spoke to everyone, got the information out, and put together what I think was a nice application approval template. We sent that around to all our clients, and they were very happy. Good. If they're happy, we're happy. Yes, exactly. We do work with the regulators to clarify that issue because it wasn't clear to us. We engaged with them. They've been very forthcoming. We appreciate that. Then we were able to share that with the industry. That was great. We're working towards the July 12th deadline. I think all the unit tests are probably in at this point, for us anyway. I'm not going to talk about my competitors. Maybe they're later than me. We'll see what happens. This is a big deal because of the semiannual, and I'm sure it's all going to go fine, and then we have one in December. The next one. That was great. I think the other things that were coming up in the AGM were Treasury clearing and repo clearing. I know that there are other trade associations that are looking at this as well, but ISDA is at the forefront of a lot of the stuff. Some of it is adjacent to the derivatives business, but some is very direct, like repo, to the derivatives business. That's why this is very involved in this. From my perspective, I look at this as a workflow solution. There's going to be a lot more volume. There's going to be a lot more collateral moving around, especially for repo. Then, we have to deal with this, and we can let people know about the deadlines. However, in terms of the role of ISDA, from your perspective, what is this role in the Treasury and repo clearing that's coming in December 2026 and then June 2027? I think I got those dates right. We talked about this earlier. It seems like it's far away, but it's never far. You never have enough time for anything. Keep in mind, this is already a year's delay, which we're grateful for. We advocated to the SEC. They recognize the workload that lies ahead of us and what has to be done. They were generous. They gave us a one-year delay, so you're right. End of 2026 for cash, mid 2027 for repo. It is an all-hands-on-deck working with FIA and SIFMA is holding the pen right now in the legal documentation. That's the first part and is essential to get good documentation. We've done the documentation, which is trading with your dealer, clear with your dealer, also working on the done away documentation. That's forthcoming. We also have three clearinghouses that will be offering services in this area, which is really going to be interesting from a commercial standpoint. We'll see how this shakes out. The incumbent DTCC FICC, has its services, and they have roughly a dozen clearing models for members and market participants to consider. CME has a partnership and an independent proposal that works with FICC. Then ICE has its rulebook, filed with the SEC and has not been published for comment yet, so we're waiting on that. You digest the rulebooks, you understand what the clearing models look like, and think about the commercial opportunity here. You mentioned the operational challenges. That's significant. Once we figure out what the clearing models are going to be and what the clients and the dealers are going to agree on in terms of that documentation, then it's about implementation. That's not insignificant. This is a new build for many people, and some new clearing structures. Therefore, pay attention if it publishes all the clearing models that we've seen thus far on our website. If you're trying to get your head around what's possible or what's available, certainly check the website out. We do a summary of that, and then you can figure out what's in your best commercial interest. The next bit of this is to make sure that Treasury clearing remains efficient. This goes to the capital treatment. This is where ISDA is putting a lot of time and effort. Back in March of last year, we put forward a letter, this 2024, asking the US Treasury and the Fed to consider offering relief under the SLR for repo. Removing repo from the denominator of SLR to make it more efficient. It's a low-risk trade. It's a high-volume trade, and it's consistent with the relief that was provided in the dash for cash in the previous Trump administration. This is not unfamiliar. This happened, but it was done under emergency circumstances. We think that should be made permanent, and I would love to see that made permanent. We've been in conversation about why we want to have repo for on-balance sheet transactions to make sure that we have enough liquidity. The other element to this is cross-product netting. Now, when you have futures, cash, and repo in one client netting set, there's a huge opportunity there. This is the mother of all netting sets, which is fantastic. It provides a client with a lot of efficiency. What we understood, though, when we looked at the capital treatment, is that the standardized approach or SACCR, repo is not part of that netting set. We have recommended to the Fed that they modify that and put repo as part of that netting set. Then you have the client and the dealer treatment consistent. That's really important to offering. Again, it's a dealer-dominated market making sure that we have good efficient markets, and you're not creating a capital treatment that's inconsistent with the netting. -Have you heard from the Fed on this yet, or is it something that? -We've been in dialogue and we've been urging, and in fact, I was recently in Washington advocating on this to make sure that we get that proposal out. The end game is also the other element, so Basel endgame. Indiana too, because you mentioned capital. Every time anyone says capital is like, what's going on with endgame? Basel, the last version that we saw it in the Biden administration, endgame had punitive capital treatment for clearing, which is completely inconsistent with where we need to be with all clearing, but particularly with Treasury clearing. We advocated against both the G sub-surcharge and the endgame client clearing requirements boosted capital. You want more clearing, but then you make it punitive. Yes, completely inconsistent. We advocated for that. The last proposal, at least by a speech by Michael Barr, was that they were going to fix that. It had an 80 percent increase in RWA, which is crazy. We think we're in a good spot, but we're going to continue to make sure that the Basel endgame, whatever format, whatever they call it under this administration, recognizes clearing benefits, the opportunity, and that it gets favorable capital agreements. The gold plating has to go. -It has to go. We've got to incentivize clearing. We at least have a risk-appropriate treatment of clearing that is not gold plating. Those three things are SLR, cross product netting, and the overall endgame in a puzzle. -Again, people watch this. I'm not going to hold you to any time frames, but I know the UK, EU, it's a waiting game to see what the US does. I know generally the Trump administration seems to be deregulation, less regulation, and sound regulation. I don't know how you want to call it. It sounds like it'll probably happen in that vein, but do we have any indication of when we think we might see this or not yet? -We don't have a specific date or time. Chair Powell has said they're going to work towards that. Miki Bowman, vice chair for supervision, is now in her role. She's responsible for taking this on. We expect that they're working quite aggressively to implement this. We'll just have to wait and see. We don't know what the timetable is, and we don't know what the overall proposal will be, but we'll be ready to comment, and hopefully on a new proposal. I want to go back, and the timetable does matter. We're recording this at the end of June, and the Feds are about to have an open meeting on the leverage ratio. We're pleased that they're going to be addressing that. We think that's really important for deep liquid Treasury markets. We've also advocated that they address the issue of cross-product netting as a separate rule-making as well. They could put it on a new Basel proposal end game, but that implementation, as you teased, could be too late to support the Treasury clearing. We've also advocated that that be an independent rulemaking to address the standardized approach of SACCR to get that fixed so everybody gets the full advantage of the cross-product netting. We'll just have to see how they phase this. We'll be commenting. We'll be soliciting views from the market. I suspect that just like a busy first half of the year, it'll be a busy second half. -Yes, and it'll probably all come in one month at the end. -As it does. As it always does. That's great, Scott. That's really interesting, and is, as always, a finger on the pulse and right in the middle of it, so we'll wait and see. Obviously, from an ELSEG perspective, I can't really comment on what you mentioned, a lot of other clearinghouses, but not us. Obviously, we are the London Clearing House, so we do clear Treasury futures, but we'll see if there's a fourth entrance at some point, but that's new to hear. Is that breaking news, John? -No, it's not. I'm not breaking any news. Anyway, that's good. It's good to know. I'm glad we've laid that out. I think it's really important to keep on top of this for our capital and optimization business, it's really important, but it's important for everyone to get clear direction, especially from a global perspective. It would be nice to have the globe walking in the same direction. -I mean, this is a really important market. The Treasury market is super important. It's a global market, so this is a global implementation. It funds the repo market. It funds so much of our non-cleared margin today, 1.5 trillion in non-cleared margin according to the latest survey. It is insignificant. -No. We want to make sure that that market stays liquid, efficient, and cost-effective. That's the whole point. Make sure that we can fund the margin, the clearing, everything else that goes with it, so that our market remains safe and efficient. That's why we exist. -That's right. Well, thank you for that. I'm going to shift gears a little bit and talk a little bit. You mentioned collateral, so we're actually segueing into it. Something that it has been doing for a little while, and I think it's a great effort because, as younger people are getting into this market and working in the derivatives industry, it's important to engage them. It's important that we hear from them, new minds, new ways of thinking about things. Is the Future Leaders in Derivatives program. You've had a few cohorts already. Four. -Four already. We were part of this last one, the collateral efficiency white paper, which I think was great, was laid out at the AGM as well. Some really good ideas in there. For me, the overall themes were around optimization, liquidity, especially during stress events. We've seen a bunch of those recently. Hopefully, I'm sure we're going to see more of those, but how collateral can move, and what types of collateral? High-quality liquid assets, and I felt like the paper was really super focused on a lot of that. There were a lot of other things, too, around new technologies and infrastructure, and stuff like that, but to me, that was the undergird, the paper which I think is important to talk about. I think a lot of things will probably come off the back of that paper. I know it does work on that already. -Yes. How important is this program for you, and what are some of the things that came out of this paper? I know we're going to have another one next year. I don't know if we can talk about that yet, but as far as this one goes, we are proud of the folks in the cohort. I know you were hands-on because I got reports myself saying that we had to present to Scott, and I'm like: "Okay, Scott has always hands on a lot of things." That was great. I was very happy to hear that, but again, from your perspective, can you just give me some of your thoughts on this paper and program? Yes. Well, the program is, as you noted, our opportunity to recruit and find the best and brightest in the industry that is maybe not engaged in the regular dialogue on either the working groups or in our conferences. We really want to build the future and appropriately name the future leaders. They will be taking over for us, so we want to make sure that they're well... -Known forever. Engaged. They are extraordinarily bright, hardworking people with a lot of strong professional backgrounds. We bring them from all geographies within the user world, and to make sure that we have a complete set. We always tasked them with an assignment at the beginning of the year. This year was collateral. We've done AI, we've done commodities, and climate and sustainability in the past, and they write a report. They all have to work together, and they do a fantastic job. We also support them through professional training. We get coaches for speech-making and other training to make sure that they're just really well-rounded professionals going forward. Then we have an alumni group that we have to support as well, so we build this really strong network, which we hope they benefit professionally, and certainly we can recruit them. We want to engage them in our conferences going forward. They bring a slightly different perspective. They're no-holds-barred, and that's this white paper. Most of it is love. We have friends flying around, and that's what I love. That's what I love about it. It's no holds barred. It's everyone just getting around the table and throwing ideas out, and the best ones win. Well, we had 16 recommendations out of this paper, and some of these proposals were considered previously, but they're like: "No, these are really important. We should go back to these things." Just because it's not current industry practice doesn't mean that it doesn't have some value. They get out of the box. -Explore AI talking about how you would get more diverse collateral, and how you think about tokenization. Really doing a lot of innovative things that we can use as we think about the future, and we certainly have them present and share that. We 100 percent support that, we've seen their paper, we've engaged with them on it, and we're behind them 110 percent. -Well, I was really proud that we were part of it. I love the result, and I think there were a lot of great ideas. Tokenization is one thing that we're going to continue to hear as digital assets become more of a reality, as they're already being used in a lot of circumstances. This is definitely going to be at the forefront, along with everything else. I think, again, we always talk about safe, efficient markets. This is part of that. How do we make it better? How do the young people teach old people like me that maybe I'm thinking about it wrong, maybe you need to think about it this way? I love that. I love the transparency and the open and honest process that is. Well done there, Scott. Well done to the cohort. Great. They worked hard. -Yes, they did. I want to switch gears a little bit now into the market's regulatory changes, which I mentioned earlier. We've talked about changes from a Biden administration to a Trump administration in terms of what's new in the SEC, at the CFTC. Now, I know that we had a couple of resignations recently. Summer had left. There are a couple of new ones, and I think Brian is maybe still on the hill. You probably know better than I. I'm not in government relations. I have a great team at LSEG that does this. I keep in touch with them as much as I can, but not in real time. However, maybe you could just give us a perspective on you being a former CFTC commissioner. What's going on at those agencies? Maybe some of the early focus is when Brian Quintenz becomes the next chair. What's his agenda? Can you share anything? Obviously, you don't have to tell us anything that isn't public, but maybe you've heard something recently that you can share and be helpful for folks. From your very unique chair, what's your perspective on those agencies now? -The question of what's new. It's certainly the leadership. Paul Atkins has been sworn in as the new chair of the SEC. He used to be a former commissioner. His term ended in 2008 previously, but he's also joined by two of his colleagues, Hester Peirce and Mark Uyeda, also well-experienced individuals. They're off and running, and they're doing a great job. Recently, for the ISDA world, they've delayed some rulemaking about data reporting, so the large swap dealer data reporting requirements, which were due to expire using substitute compliance at the end of this year, kicked off for four years. I think you are beginning to see their agenda coming through. It's still early days, but I think they're looking very carefully at where they can make reforms to existing rules to make the market stronger, make markets better, and get rid of regulation that doesn't make sense. It's not to say that wholesale is going to cut the regulatory environment. I don't worry about that at all, actually. In fact, they were very clear that the Treasury Clearing Mandate is going forward. We spent time that... -I was going to ask you, too. People ask us: "Is this going to change again because we got a delay?" No, that was your first and only delay because of what we heard, so let's get on with it. As you mentioned, Brian is going through the nominations process. He had a very good hearing on the Senate. I think I'm optimistic that his nomination and he'll be able to get into the CFTC this summer. Maybe as early as before the July 4th break, which would be fantastic. That'd be great. -Brian's a former CFTC commissioner. He replaced me. He wisely hasn't disclosed his agenda before he gets the job, but I'm sure he has some ideas of where he can... Crypto. -He's thinking about some reforms. Crypto is consuming Washington right now. The House and Senate have passed their stablecoin legislation. The House committees passed their market structure for crypto, so it's full on. The conversation in Washington right now is all about crypto in the market structure issue. That will continue to play through this summer and probably early fall, but I do think both the House and the Senate will pass respective bills that will create a new market structure and regulatory clarity, which is important. I think that's an area where ISDA has to contribute in certain areas around the definitions of crypto, making sure that we have a good rule of law and clarity around certain definitions for derivatives in crypto. We'll work on the custody treatment of this as well to make sure that that's clear and bankruptcy is well-defined. I think that's our role. We don't have to get involved in everything. We don't have to solve everything, but we want to make sure that we have a good level playing field that recognizes and clarifies the regulatory treatment of crypto. Well, thanks for that, Scott. Now, for our last thing, I always like to talk about what's going on in the world. Obviously, there's a ton of volatility from the beginning of the year with Trump's tariffs. We have a lot of geopolitical things going on. I don't know if I want to use the word risk. We still have Russia-Ukraine, we have Israel-Iran right now, and we're getting involved. It all has an effect on the markets, and it affects our derivatives markets. I say ours because we're in it. Any perspectives on that in terms of what it means for the derivatives markets, if at all, and really, what role do you think we play when things are going in this direction and in this environment? Well, first of all, as part of our 40th anniversary, we did release the Value of Derivatives report and a stocktake as to who uses them and why. The reality is that thousands of firms worldwide, across all jurisdictions, are using derivatives. Well, over 80 percent of the firms that we surveyed use derivatives to manage risk and it is a global market. The derivatives market, but also managing risk and investment across the globe. I have the opportunity and the benefit to crisscross the globe, to talk to policymakers all around the world about the value of derivatives and the importance to their economies and why risk management around interest rate risk or equity markets, making sure you have diversity, both either cleared or a non cleared space to give participants a way to manage their risk and take a view on the markets. As you pointed out, yes, geopolitical concerns are all over the place. You have an interest rate environment right now that is changing quite a bit in most countries lowering of interest rates. However, the interest rate on the curve is reflecting a short-term geopolitical issue. Then, long-term on financial stability, in the question of where economies are, where's the US going to be in terms of its debt, et cetera. Managing that curve and helping firms manage risk all over the world. Whether FX, equity, credit, et cetera, matter. You've seen with a less strong economy or a weakening economy, you think about some of the CVS issues that you want to make sure you manage the counterparty risk and the threat that the bonds could default. All of these things are at play, bringing much more attention and focus to our market. We believe now more than ever, derivatives are relevant and important, and that the alternative to not managing your risk is taking on more risk. We want to make sure that we talk to policymakers around this, and maybe dispel some myths about the market and some legacy concerns about bringing risk into a market and the role derivatives have. We want to dispel that as well as highlight the importance of that, and then how we think about the policy implementation is connected, so capital treatment, market structure issues, and liquidity. We've gone through a whole regulatory change. It was all about managing counterparty risk. Now we're really focusing a lot more on liquidity risk and making sure episodic markets or fragile markets don't spiral out of control. We've seen some of these dash for cash LDI crises. It's really a full-time job. We're active on it. It's an interesting and rewarding job because it involves developing solutions to help the market. We talked about SIMM earlier on a podcast about how firms manage their counterparty risk. How do they get a model that's approved by regulators, supported, used, and is cost-effective? Something else they can do is make sure that capital trade is well-defined and risk-appropriate. Lots of things that we're working on right now to make sure that derivatives are safe and efficient, as the logo says. -Yes, absolutely. Well, I'm always glad. Again, I come at it very biased. For people who are listening to this, I worked with you, Scott. You were my boss, my colleague for many years, so ISDA plays a big role in our business. They're near and dear to my heart, and I'm glad that you're there and do all the great things that you just laid out, and there is even a lot more than what we were talking about today. That's great. Thank you for that roundup. Thank you for coming. I think we're done. I'm always used to having any other business section in all of my agendas. Is there anything that you want to plug for ISDA? I know there are a lot of other things going on. Anything you want to plug before we go? We're in a very important time now in terms of implementing the Notices Hub and a couple of other solutions. The Notices Hub is to manage counterparty risk, and certainly in the event of a default, it's just a better way of executing defaults and terminations between counterparties. We learned after Lehman, after the dash for cash, and the Covid crisis, and then after the Russia sanctions. The ISDA master agreement requires delivery physically, and when Lehman had moved offices and it defaulted to the entire industry, we had to deliver those notices. -I remember that. Dash for cash, delivering to empty offices, and then Russia delivering to a country that did not want to be delivered to. Each of these has its own problems, but we've learned from this. We've created, working with S&P, a technology solution that counterparties will deliver to the central Notices Hub. Then emails will go out or text or whatever form you want to communicate that. That is an absolute lock-in. This is when it happened, auditable, transparent, and very efficient. You're not worried about, did the messenger get to the building? Did they deliver it to the correct building? Because updating the documentation isn't always a priority, so you find legacy documents could have the wrong address or the wrong individual identified in that. We want to make sure that we update that consistently and accurately on a regular basis, so we will have a technology solution to do that. Now we're also supporting this with an ISDA protocol. From June 11th until our go-live on July 15th, we're asking the industry to sign up for a pre-adherence period to a protocol to adjust all of your documentation. By doing that, counterparties can agree to this. We'll publish that. Then you can begin to use the Notices Hub when we go live on July 15th. We're also supporting that, as this is a global market, with netting opinion or opinions to say that this delivery mechanism will work in your jurisdiction. We have 20 priority jurisdictions of the largest, most relevant jurisdictions right now. Those will be ready by go-live on July 15th. Then we're going to finish out the rest of the protocols or the rest of the opinions through the end of the year. We will have a much better automated solution. It's already the same service that the counterparty manager is already connecting to your services today, so this is not a new interconnect. It is just an expanded service of what's being offered. Therefore, it obviously makes interconnection and onboarding much easier, so we were asking the industry to join up, come onto this platform to support it, so you have a much more accurate and timely way of delivering termination notices. -It made sense, and obviously, you mentioned S&P. They're a competitor of ours in a couple of ways, but you already had some established, especially from the protocol perspective, so it made sense to extend that. That totally makes sense. It goes hand in hand, and it makes sense. There's no reason to reengineer anything else. You already had the pipes and everything else plugged in, but it was a good idea, and I'm glad that it's coming to fruition, and it sounds like it's ready to go. -We've had good market uptake. Many firms understand that this is the right solution at the right time, and it is the future. In the future, we do think we can expand this to other documents, other services, et cetera, but we're going to start with the basics, and we have to deliver that. We do that well, then we earn the right to expand the solutions going forward. I should also point out that it is also doing a lot on the digital reg reporting using the common domain model. I think we're having a lot of success there. More and more firms are coming onto that. More and more firms are developing POCs to figure out how they onboard to get a more accurate reporting across multiple jurisdictions. We've had J.P. Morgan as a big supporter of this. BNP and Pictet have also been on board. We've got many other firms joining in that testing phase, and they're going to go live with the new implementations. ISDA will continue to support this. Every time regulators change the rules and update the rules, we will be there to push out new solutions so you can accurately report. I should point out that over the past decade, we pulled these numbers, $285 million was paid in penalties and fines by the industry in just the past decade in the US, EU, and UK. We want to bring that number to zero. We do have some important implementations. Hong Kong, and Canada went live this year. We have MiFID in Europe again coming forward, so there's more to be done there. Great. Those are big numbers. Great, Scott. Thank you for that. Obviously, from an LSEG's solutions perspective, we're involved in MiFID Neg reporting as well. Also, CDM is always something that we're we're looking at and implementing as well. Thank you for that. Listen, this was great. I know we had a little fly running around. Hopefully, that doesn't distract our listeners, but we apologize for that. This was a great conversation. Thank you so much again for joining us today, spending time with us. It's always great to see you, and hopefully you come back again. -Oh, I'll be back. You invite, I will show up. Thank you very much for having me. Thank you, Scott. Thank you. Thank you again for joining us on our podcast. I had a great conversation with Scott. I hope you enjoyed it. I know I did. You can find us on all of your streaming services, Spotify, YouTube, and on LSEG.com. Thanks again for joining us, and we'll see you again soon. Bye.