synthetic collateralized debt obligations (CDOs). There were two Bistros in 1997 for approximately $10 billion each. Mindful of the concentration of default risk as one of the causes of the S&L crisis, regulators initially found CDS's ability to disperse default risk attractive. In 2000, credit default swaps became largely exempt from regulation by both the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC). The Commodity Futures Modernization Act of 2000, which was also responsible for the Enron loophole, specifically stated that CDSs are neither futures nor securities and so are outside the remit of the SEC and CFTC. Market growth At first, banks were the dominant players in the market, as CDS were primarily used to hedge risk in connection with their lending activities. Banks also saw an opportunity to free up regulatory capital. By March 1998, the global market for CDS was estimated at $300 billion, with JP Morgan alone accounting for about $50 billion of this. The high market share enjoyed by the banks was soon eroded as more and more asset managers and hedge funds saw trading opportunities in credit default swaps. By 2002, investors as speculators, rather than banks as hedgers, dominated the market. National banks in the USA used credit default swaps as early as 1996. In that year, the Office of the Comptroller of the Currency measured the size of the market as tens of billions of dollars. Six years later, by year-end 2002, the outstanding amount was over $2 trillion. Although speculators fueled the exponential growth, other factors also played a part. An extended market could not emerge until 1999, when ISDA standardized the documentation for credit default swaps. Also, the 1997 Asian Financial Crisis spurred a market for CDS in emerging market sovereign debt. In addition, in 2004, index trading began on a large scale and grew rapidly. The market size for Credit Default Swaps more than doubled in size each year from $3.7 trillion in 2003. By the end of 2007, the CDS market had a notional value of $62.2 trillion. But notional amount fell during 2008 as a result of dealer "portfolio compression" efforts (replacing offsetting redundant contracts), and by the end of 2008 notional amount outstanding had fallen 38 percent to $38.6 trillion. Explosive growth was not without operational headaches. On September 15, 2005, the New York Fed summoned 14 banks to its offices.