Traditionally, counterparties executing swaps transactions in the unregulated Over-The-Counter (“OTC”) marketplace maintained entire teams of staff devoted to the credit or delivery risk of a counter-party. Inclusive in this regime was the preeminent notion that brokers never held client funds of any kind. This key discrepancy may cause various regulatory outtrades between regulators and parties in the Introducing Broker regime, most notably the legacy swap broker and the traditional Introducing Broker (“IB”). With the move to central counter-party clearing, it is likely that legacy swaps firms will see a cost-shift to that of compliance. The rules promulgated in response to…