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Concept

The request for quote protocol represents a foundational method for sourcing liquidity, particularly for instruments or trade sizes that demand discreet, targeted price discovery. An institution transmits a request to a select group of liquidity providers, who respond with their best offer. The initiating firm then selects the most favorable quote to execute the transaction. This entire process, from solicitation to execution, establishes a direct, bilateral relationship.

The creditworthiness of each counterparty is a direct variable in the execution equation. The risk is that the opposing firm in the trade ▴ the counterparty ▴ fails to meet its obligations, such as delivering the securities or paying for them. In a bilateral RFQ system, this risk is borne directly by the participants. Each trade creates a unique, uncollateralized exposure to a specific counterparty.

Central clearing introduces a new architectural layer into this system. A central counterparty clearing house (CCP) inserts itself between the two original trading parties. The mechanism for this is called novation. The original contract between the buyer and seller is extinguished and replaced by two new contracts ▴ one between the buyer and the CCP, and another between the seller and the CCP.

The CCP becomes the buyer to every seller and the seller to every buyer. This architectural change fundamentally re-engineers the flow of risk. The direct, bilateral exposure between the two trading firms is severed. In its place, each firm now faces the CCP. The counterparty risk is no longer fragmented across numerous individual firms; it is consolidated and managed by a single, highly regulated, and specialized entity.

Central clearing transforms diffuse, bilateral counterparty risk into a managed, standardized exposure to a central entity.

This transformation is supported by a robust risk management framework operated by the CCP. The core components of this framework are the margining system and the default waterfall. Every participant in the clearinghouse must post collateral, known as margin, which is calculated to cover potential losses in case of their default. The default waterfall is a predefined sequence of financial resources that the CCP will use to absorb losses if a member defaults and their margin is insufficient.

This system is designed to ensure that the failure of one or even multiple members does not cascade through the financial system. The CCP’s role is to act as a circuit breaker, absorbing the shock of a default and preventing it from propagating. The impact on RFQ trading is profound. The protocol for price discovery remains the same, but the post-trade risk profile is completely altered. The focus of risk management shifts from assessing the creditworthiness of every potential trading counterparty to understanding the risk management framework of the single CCP.

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What Is the Primary Function of a CCP?

The primary function of a Central Counterparty (CCP) is the mitigation of counterparty credit risk through the process of novation and the management of a collective risk pool. By becoming the counterparty to every trade, the CCP standardizes and centralizes the management of risk that would otherwise be a complex web of bilateral exposures. This centralization allows for multilateral netting of exposures, which significantly reduces the total amount of risk in the system. Instead of managing credit lines and collateral agreements with dozens or hundreds of individual counterparties, a firm manages a single exposure to the CCP.

The CCP, in turn, implements a rigorous, transparent, and regulated risk management system that is its sole focus. This includes setting margin requirements based on the risk of each member’s portfolio, maintaining a default fund to cover extraordinary losses, and establishing clear procedures for handling a member’s default. The CCP’s function is to provide a utility for the market that increases stability and efficiency by managing the interconnectedness of its participants.

This operational focus allows market participants to transact with a wider range of counterparties than they might otherwise be comfortable with in a purely bilateral market. A firm’s willingness to respond to or solicit an RFQ is no longer constrained by the perceived credit risk of the other party. The constraint becomes the firm’s ability to meet the CCP’s margin requirements.

This can democratize access to liquidity and improve overall market depth. The CCP’s function is to create a more resilient and efficient market structure by absorbing and managing the risk of default, thereby allowing market participants to focus on their primary business of trading and investment.


Strategy

The strategic integration of central clearing into RFQ workflows is a decision driven by capital efficiency, risk management, and market access. In a bilateral RFQ environment, every trade adds to a gross calculation of counterparty exposure. A firm might have two trades of equal and opposite value with two different counterparties, but these exposures do not offset each other. The firm still carries the full default risk of both counterparties.

This has direct capital implications. Regulatory frameworks require firms to hold capital against their counterparty credit risk exposures. As these exposures grow, so does the amount of regulatory capital that must be set aside, which is a direct cost to the firm.

Central clearing provides a strategic solution to this problem through multilateral netting. When trades are cleared through a CCP, all of a firm’s positions with that CCP are treated as a single portfolio. The CCP calculates the net exposure of this portfolio. The two equal and opposite trades that created a large gross exposure in the bilateral world are now netted against each other, resulting in a much smaller, or even zero, net exposure.

This has a powerful effect on a firm’s balance sheet. The reduction in net exposure leads to a corresponding reduction in the amount of regulatory capital required. This freed-up capital can be deployed for other purposes, such as increasing trading activity or returning it to shareholders. The strategic decision to use central clearing is therefore a calculation of the costs of clearing (such as margin requirements and clearing fees) versus the benefits of reduced capital charges and mitigated risk.

Multilateral netting through a CCP is a key strategy for optimizing a firm’s balance sheet and reducing regulatory capital burdens.

Another strategic dimension is the management of liquidity. In a bilateral market, a firm might be hesitant to trade with a smaller or less creditworthy counterparty, even if that counterparty is offering the best price. This can lead to fragmented liquidity and suboptimal execution. Central clearing removes this barrier.

As long as a counterparty is a member of the CCP, they are considered a valid trading partner because the ultimate credit risk lies with the CCP. This allows firms to access a much wider pool of liquidity and focus solely on achieving the best execution price. The RFQ process becomes more efficient as the universe of potential counterparties expands. This strategy can be particularly valuable in less liquid markets or for large block trades, where finding a suitable counterparty can be challenging.

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Comparing Bilateral and Centrally Cleared RFQ Workflows

The operational and risk management workflows for bilateral and centrally cleared RFQ trading are structurally different. The following table outlines the key stages and strategic considerations for each approach, providing a clear comparison of their respective architectures.

Process Stage Bilateral RFQ Workflow Centrally Cleared RFQ Workflow
Counterparty Selection

Selection is limited to counterparties with whom the firm has established bilateral credit agreements (ISDAs) and sufficient credit lines. The creditworthiness of each potential counterparty must be actively managed.

Selection can include any member of the CCP. The primary consideration is the counterparty’s ability to provide competitive pricing, as the credit risk is mutualized by the CCP.

Risk Assessment

Risk is assessed on a per-counterparty basis. The firm must calculate its gross exposure to each counterparty and hold capital against this exposure. This requires a significant investment in credit risk modeling and management.

Risk is assessed at the portfolio level against the CCP. The firm’s exposure is its net position with the CCP, which benefits from multilateral netting. The primary risk assessment shifts to the CCP’s own risk management framework.

Collateral Management

Collateral is exchanged bilaterally based on the terms of individual credit support annexes (CSAs). This can be a complex and operationally intensive process, with multiple margin calls and settlements each day.

Collateral (Initial and Variation Margin) is posted to the CCP. The process is standardized and centralized, reducing operational overhead. Margin calculations are performed by the CCP based on its approved models.

Default Management

In the event of a counterparty default, the surviving firm must manage the close-out process directly. This can involve lengthy legal proceedings and significant potential losses beyond any collateral held.

In the event of a member default, the CCP manages the default process. It uses the defaulting member’s margin and default fund contributions to cover losses and, if necessary, its own capital and the default fund contributions of other members. The process is designed to be swift and to prevent contagion.

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How Does Clearing Alter Trading Incentives?

The introduction of a CCP alters the incentive structure for market participants. In a bilateral system, there is a strong incentive to trade only with the most creditworthy counterparties, which can lead to a concentration of risk in a few large institutions. Central clearing changes this by creating a more level playing field.

The mutualized risk model of the CCP, supported by the default waterfall, provides a baseline level of security for all participants. This encourages trading with a wider variety of counterparties, which can improve market liquidity and price discovery.

The margining system also creates powerful incentives for risk management. Because margin requirements are calculated based on the risk of a firm’s portfolio, firms are incentivized to manage their risk in order to reduce their margin costs. This can include hedging their positions more effectively or avoiding excessive concentration in risky assets. The CCP’s risk model acts as a disciplinary force, rewarding prudent risk management with lower costs.

This aligns the incentives of individual firms with the overall stability of the financial system. The result is a market where risk is more transparently priced and managed, and where the costs of excessive risk-taking are borne more directly by those who take the risks.

  • Capital Efficiency ▴ The primary incentive is the reduction of regulatory capital charges through multilateral netting. This frees up capital for more productive uses.
  • Market Access ▴ Clearing provides access to a wider range of counterparties, improving liquidity and the potential for price improvement in RFQ execution.
  • Risk Management Discipline ▴ The CCP’s margining system creates a direct financial incentive for firms to manage their portfolio risk effectively.
  • Operational Simplification ▴ Centralizing post-trade processes like collateral management and settlement reduces operational complexity and cost compared to managing multiple bilateral relationships.


Execution

The execution of a centrally cleared RFQ trade involves a precise sequence of operational steps that interface with the CCP’s architecture. While the pre-trade price discovery process remains a bilateral negotiation, the post-trade lifecycle is fundamentally re-engineered. The transition from a bilateral contract to two centrally cleared contracts is a critical phase governed by the CCP’s rules and technological protocols. Understanding this execution flow is essential for any firm seeking to leverage the benefits of central clearing.

The process begins the moment the RFQ is accepted. The two counterparties have agreed on a price and quantity. At this point, the trade details are submitted to the CCP for registration. This is typically done through a standardized messaging format, such as the Financial Information eXchange (FIX) protocol, or via a proprietary API provided by the CCP or a clearing member.

The CCP then validates the trade details and checks that both counterparties are members in good standing with sufficient resources to support the trade. This includes checking that the trade will not breach any position limits and that the firms have sufficient pre-funded collateral to meet the initial margin requirement for the new position.

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The Operational Playbook for Trade Novation

The novation process is the core of the execution workflow. It is the legal and operational mechanism by which the CCP becomes the central counterparty. The following steps outline a typical operational playbook for the novation of an RFQ trade:

  1. Trade Agreement ▴ The initiator of the RFQ accepts a quote from a responding liquidity provider. A bilateral trade is legally formed at this moment.
  2. Trade Submission ▴ Both counterparties, or their clearing members, submit the matched trade details to the CCP. This submission must be timely, typically within minutes of the trade agreement. The submission includes key data points such as the instrument, price, quantity, and the identities of the original counterparties.
  3. CCP Validation ▴ The CCP’s systems perform a series of automated checks. These include verifying that the trade details from both parties match, confirming that both parties are active members of the clearing service, and assessing the initial margin impact of the trade.
  4. Margin Calculation and Verification ▴ The CCP calculates the initial margin that will be required for the new position. It then verifies that both counterparties have sufficient collateral on deposit to cover this requirement. If a firm’s existing collateral is insufficient, it will receive a margin call and must post additional collateral before the trade can be accepted for clearing.
  5. Novation and Registration ▴ Once all checks are passed and margin requirements are met, the CCP accepts the trade. At this point, novation occurs. The original bilateral contract is legally extinguished and replaced by two new contracts. The CCP is now the buyer to the seller and the seller to the buyer. The trade is officially registered in the CCP’s records.
  6. Confirmation ▴ The CCP sends a confirmation message back to both counterparties (or their clearing members) confirming that the trade has been successfully cleared. The trade now becomes part of each firm’s centrally cleared portfolio.
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Quantitative Modeling of the CCP Default Waterfall

The resilience of the central clearing system rests on the architecture of the CCP’s default waterfall. This is a sequence of pre-funded and contingent financial resources designed to absorb the losses from a defaulting member. The structure of this waterfall is a critical element for any firm to analyze when assessing the risk of using a particular CCP. The table below provides a quantitative model of a hypothetical CCP default waterfall, illustrating the layers of protection and their capacity to absorb losses from a major default event.

Waterfall Layer Description Hypothetical Resource Amount (USD) Cumulative Coverage (USD)
1. Defaulting Member’s Initial Margin

Collateral posted by the defaulting member to cover potential future exposure of their portfolio. This is the first line of defense.

$1,500,000,000

$1,500,000,000

2. Defaulting Member’s Default Fund Contribution

The defaulting member’s contribution to a mutualized default fund. This is consumed after their initial margin is exhausted.

$250,000,000

$1,750,000,000

3. CCP’s Own Capital Contribution (“Skin-in-the-Game”)

A portion of the CCP’s own capital that is committed to the default waterfall. This aligns the CCP’s incentives with those of its members.

$500,000,000

$2,250,000,000

4. Non-Defaulting Members’ Default Fund Contributions

The mutualized contributions of all other, non-defaulting members to the default fund. This is the primary layer of loss mutualization.

$7,500,000,000

$9,750,000,000

5. Further Loss Allocation (e.g. Cash Calls)

Contingent assessments on non-defaulting members to cover any remaining losses. This is a recovery tool used in extreme stress scenarios.

Up to 2x initial Default Fund Contribution

Variable, up to $24,750,000,000

This quantitative model demonstrates the depth of the financial resources available to a CCP. The layered approach ensures that the risk is managed in a sequential and predictable manner. The vast majority of default events would be fully covered by the defaulting member’s own resources (Layer 1 and 2).

The mutualized layers (Layer 4 and 5) are reserved for extreme, systemic events. The size of these layers, particularly the default fund, is typically calibrated to withstand the simultaneous default of the two largest members, a standard known as “Cover 2.”

The default waterfall is the ultimate backstop that transforms counterparty risk from an idiosyncratic, bilateral problem into a managed, systemic solution.
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What Are the Limits of Central Clearing?

While central clearing is a powerful tool for risk mitigation, it is not a panacea. The system concentrates risk in the CCP itself. The failure of a CCP would be a catastrophic event with far-reaching consequences for the entire financial system.

Therefore, the robust regulation and oversight of CCPs are of paramount importance. The risk management practices of the CCP, the adequacy of its default waterfall, and its recovery and resolution plans must be subject to intense scrutiny by regulators and market participants alike.

Furthermore, central clearing introduces new types of risk. Liquidity risk is a major concern. In a crisis, a firm may face large margin calls from the CCP and may have difficulty raising the necessary cash or eligible collateral. This could force the firm to liquidate assets at fire-sale prices, exacerbating the crisis.

There is also model risk. The CCP’s margin models may fail to accurately predict the risk of a member’s portfolio, leading to insufficient collateral being collected. Finally, there is the risk of procyclicality. In a volatile market, margin requirements will increase across the board, which can amplify market stress by forcing all firms to de-leverage at the same time. Understanding these limitations is a crucial part of a comprehensive strategy for using central clearing.

  • Concentration Risk ▴ The CCP itself becomes a single point of failure. Its failure would have systemic implications.
  • Liquidity Risk ▴ The need to meet margin calls in cash or high-quality liquid assets can be a significant challenge during times of market stress.
  • Model Risk ▴ The CCP’s margin models may be imperfect, leading to an underestimation of risk and insufficient collateralization.
  • Procyclicality ▴ Rising margin requirements in volatile markets can force widespread de-leveraging, potentially amplifying a crisis.

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References

  • Ghamami, Samim, Mark Paddrik, and Simpson Zhang. “Central Counterparty Default Waterfalls and Systemic Loss.” Office of Financial Research, Working Paper, 2020.
  • Cont, Rama. “The End of the Waterfall ▴ Default Resources of Central Counterparties.” Journal of Risk Management in Financial Institutions, vol. 8, no. 4, 2015, pp. 365-389.
  • Paddrik, Mark, Samim Ghamami, and Simpson Zhang. “Central Counterparty Default Waterfalls and Systemic Loss.” Journal of Financial and Quantitative Analysis, vol. 57, no. 8, 2022, pp. 3045-3083.
  • Capponi, Agostino, Jessie Jiaxu Wang, and H. Peyton Young. “A Theory of Collateral Requirements for Central Counterparties.” American Economic Review, vol. 112, no. 1, 2022, pp. 1-45.
  • Duffie, Darrell, and Haoxiang Zhu. “Does a Central Clearing Counterparty Reduce Counterparty Risk?” Review of Asset Pricing Studies, vol. 1, no. 1, 2011, pp. 74-95.
  • Ghamami, Samim. “Central Counterparty Default Waterfalls and Systemic Loss.” Presentation at the Financial Stability Conference, Federal Reserve Bank of Cleveland, 2019.
  • Menkveld, Albert J. “The Wobbly Pillar of the New Financial Architecture.” Journal of Financial Stability, vol. 49, 2020, 100763.
  • Yadav, Yesha. “The Failure of For-Profit Clearing.” University of Pennsylvania Law Review, vol. 161, no. 6, 2013, pp. 1775-1826.
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Reflection

The architecture of risk management is a core component of any institutional trading strategy. The integration of central clearing into RFQ trading represents a fundamental shift in that architecture, moving from a distributed, bilateral model to a centralized, standardized one. The analysis of this shift requires a deep understanding of the mechanics of novation, the structure of the default waterfall, and the second-order effects on capital and liquidity. The knowledge gained from this exploration should prompt a critical review of your own firm’s operational framework.

How is counterparty risk currently measured and managed? What are the hidden costs of the existing bilateral system in terms of capital allocation and constrained market access? The decision to adopt central clearing is not merely a technical one; it is a strategic choice about the design of your firm’s risk operating system. The optimal design will depend on your firm’s specific risk appetite, capital structure, and trading objectives. The path forward lies in viewing these market structures not as static constraints, but as configurable components in a dynamic system of institutional advantage.

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Glossary

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Price Discovery

Meaning ▴ Price Discovery, within the context of crypto investing and market microstructure, describes the continuous process by which the equilibrium price of a digital asset is determined through the collective interaction of buyers and sellers across various trading venues.
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Central Counterparty

Meaning ▴ A Central Counterparty (CCP), in the realm of crypto derivatives and institutional trading, acts as an intermediary between transacting parties, effectively becoming the buyer to every seller and the seller to every buyer.
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Central Clearing

Meaning ▴ Central Clearing refers to the systemic process where a central counterparty (CCP) interposes itself between the buyer and seller in a financial transaction, becoming the legal counterparty to both sides.
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Counterparty Risk

Meaning ▴ Counterparty risk, within the domain of crypto investing and institutional options trading, represents the potential for financial loss arising from a counterparty's failure to fulfill its contractual obligations.
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Ccp

Meaning ▴ In traditional finance, a Central Counterparty (CCP) is an entity that interposes itself between counterparties to contracts traded in one or more financial markets, becoming the buyer to every seller and the seller to every buyer.
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Risk Management Framework

Meaning ▴ A Risk Management Framework, within the strategic context of crypto investing and institutional options trading, defines a structured, comprehensive system of integrated policies, procedures, and controls engineered to systematically identify, assess, monitor, and mitigate the diverse and complex risks inherent in digital asset markets.
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Default Waterfall

Meaning ▴ A Default Waterfall, in the context of risk management architecture for Central Counterparties (CCPs) or other clearing mechanisms in institutional crypto trading, defines the precise, sequential order in which financial resources are deployed to cover losses arising from a clearing member's default.
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Risk Management

Meaning ▴ Risk Management, within the cryptocurrency trading domain, encompasses the comprehensive process of identifying, assessing, monitoring, and mitigating the multifaceted financial, operational, and technological exposures inherent in digital asset markets.
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Rfq Trading

Meaning ▴ RFQ (Request for Quote) Trading in the crypto market represents a sophisticated execution method where an institutional buyer or seller broadcasts a confidential request for a two-sided quote, comprising both a bid and an offer, for a specific cryptocurrency or derivative to a pre-selected group of liquidity providers.
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Multilateral Netting

Meaning ▴ Multilateral netting is a risk management and efficiency mechanism where payment or delivery obligations among three or more parties are offset, resulting in a single, reduced net obligation for each participant.
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Credit Risk

Meaning ▴ Credit Risk, within the expansive landscape of crypto investing and related financial services, refers to the potential for financial loss stemming from a borrower or counterparty's inability or unwillingness to meet their contractual obligations.
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Margin Requirements

Meaning ▴ Margin Requirements denote the minimum amount of capital, typically expressed as a percentage of a leveraged position's total value, that an investor must deposit and maintain with a broker or exchange to open and sustain a trade.
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Default Fund

Meaning ▴ A Default Fund, particularly within the architecture of a Central Counterparty (CCP) or a similar risk management framework in institutional crypto derivatives trading, is a pool of financial resources contributed by clearing members and often supplemented by the CCP itself.
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Capital Efficiency

Meaning ▴ Capital efficiency, in the context of crypto investing and institutional options trading, refers to the optimization of financial resources to maximize returns or achieve desired trading outcomes with the minimum amount of capital deployed.
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Regulatory Capital

Meaning ▴ Regulatory Capital, within the expanding landscape of crypto investing, refers to the minimum amount of financial resources that regulated entities, including those actively engaged in digital asset activities, are legally compelled to maintain.
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Centrally Cleared

The Uncleared Margin Rule raises bilateral trading costs, making central clearing the more capital-efficient model for standardized derivatives.
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Counterparty Default

Meaning ▴ Counterparty Default, within the financial architecture of crypto investing and institutional options trading, signifies the failure of a party to a financial contract to fulfill its contractual obligations, such as delivering assets, making payments, or providing collateral as stipulated.
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Default Fund Contributions

Meaning ▴ Default Fund Contributions, particularly relevant in the context of Central Counterparty (CCP) models within traditional and emerging institutional crypto derivatives markets, refer to the pre-funded capital provided by clearing members to a central clearing house.
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Collateral Management

Meaning ▴ Collateral Management, within the crypto investing and institutional options trading landscape, refers to the sophisticated process of exchanging, monitoring, and optimizing assets (collateral) posted to mitigate counterparty credit risk in derivative transactions.
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Cleared Rfq

Meaning ▴ A Cleared RFQ (Request for Quote) refers to a financial transaction, initiated via a request for quote mechanism, that is subsequently processed and guaranteed by a central clearing counterparty (CCP).
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Initial Margin

Meaning ▴ Initial Margin, in the realm of crypto derivatives trading and institutional options, represents the upfront collateral required by a clearinghouse, exchange, or counterparty to open and maintain a leveraged position or options contract.
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Novation

Meaning ▴ Novation is a legal process involving the replacement of an original contractual obligation with a new one, or, more commonly in financial markets, the substitution of one party to a contract with a new party.