There is no regulated CDS market, it's all over the counter and dominated by about 5 issuers of CDS. CDS market players have resisted tooth and nail any suggestion of central clearinghouses for CDS, or any of a number of more intrusive regulatory suggestions such as requiring the delivery of a defaulted bond in order to collect the value of a CDS.

CDS issuers have been shown repeatedly to be inadequately capitalised to face an actual default on the underlying, which smells of a scam where CDS premiums are collected with no intention of paying up.

The brainless should not be in banking -- Willem Buiter