What's the difference if you take interest risk wrapped in a bond, a swap or a a future? BBG starts the process of exploring the sense in the CFTC deciding what's liquid in a default, and therefore how long the IM holding period should be. It will be interesting to see whether the CFTC or CME can defend the rationale for a 2 day IM period on Deliverable Swap Futures by providing full details of the way a default would be managed by an exchange, and whether a portfolio can be sold or auctioned any more easily or quickly in one environment (Exchange) versus another (OTC) for the same portfolio. Bloomberg sues CFTC over derivatives rules – FT.com.