ISDA backed up December survey opinon with a January cleared transaction volumes analysis to show that CFTC's SEF rules already shifted D2D IRS volume offshore from the US.

December ISDA survey: – SEF rules pushed trading offshore

ISDA published a survey of 44 participants who in summary opined that as a result of CFTC's October 2nd SEF rules trading had been curtailed, shifted away from US persons and away from eTrading in favor of voice.  All because of the SEF rules footnote 88 – which went live October 2nd – making people think twice about trading with a US person – either because they are not ready or not willing.

This chimes with what I'm hearing but it's possible participants are responding to a bit of a loaded question.  "They would say that woundn't they?" – I hear you say.  

January ISDA volume analysis: – the offshore move is a fact for cleared D2D IRS

ISDA published an analysis of LCH Swapclear¹ D2D cleared swaps and DTCC SEF on platform swaps – focusing on IRS in EUR or USD.  Based on Swapclear cleared D2D volume data, ISDA deduced that European dealers reduced their trading with US dealers in EUR and also USD IRS (highlighted in the table below).  US dealers continued to trade in roughly the same proportion between European and US dealers.

So the figures highlighted below show that after October 2nd 2014 European dealers shifted ~16% of their total EUR IRS volume away from US dealers to European dealers (and also ~5% of their USD IRS volume).  

Table: Shift in Volume Share between D2D Counterparty Location from Q1-3 to Q4 2013

It's worth reading the full survey / analysis details at the link above for more context.

When MAT comes what happens?

Those pro-SEF posse hope there's more significant SEF liquidity to suck onshore the hesitators.  The anti-SEF crew think it will make more pronounced offshoring effect as non-US persons continue not to trade with US persons.  

Aside from perhaps an intial liquidity hiccup in the early days after Feb 16th, only time will tell the permanent effect.

Foot note:  1.  Swapclear is believed to dominate D2D cleared IRS.  C2D cleared IRS is more evenly split with CME.