Interest Rate Swaps $46 Million Antitrust Class Action Settlement

A $46 million settlement has been approved by federal court to compensate investors harmed by what prosecutors allege was a coordinated scheme among ten...

A $46 million settlement has been approved by federal court to compensate investors harmed by what prosecutors allege was a coordinated scheme among ten major Wall Street banks to manipulate the interest rate swaps market. Combined with an earlier $25 million settlement from Credit Suisse, the total recovery reaches $71 million for a class of investors who entered into interest rate swap transactions between January 1, 2008, and June 10, 2024. The settlement, which received final court approval on July 17, 2025, resolves allegations that JPMorgan Chase, Goldman Sachs, Citigroup, BNP Paribas, Bank of America, Morgan Stanley, UBS, Barclays, Deutsche Bank, and NatWest conspired to restrict competition and maintain unfairly high prices in one of the world’s largest financial derivatives markets. This article explains what the settlement covers, who can claim compensation, how much eligible participants may receive, and what the approval means for investors.

The lawsuit began in 2016 as a multi-district litigation in the U.S. District Court for the Southern District of New York (Case No. 1:16-md-02704-JPO). Plaintiffs including the Los Angeles County Employees Retirement Association (LACERA) and the Public School Teachers’ Pension and Retirement Fund of Chicago challenged the banks’ practices and accused them of boycotting three emerging trading platforms that offered more transparent pricing. The settlement framework was established on June 10, 2024, with preliminary approval following on July 11, 2024, and formal court approval granted nearly a year later after notice was distributed to all affected parties.

Table of Contents

What Were the Banks Accused of Doing in the Interest Rate Swaps Market?

The ten defendant banks were accused of engaging in coordinated, anticompetitive conduct designed to protect their dominant position in interest rate swaps trading. Rather than allowing market forces to determine pricing, plaintiffs alleged the banks maintained what the legal filings describe as a “collusive and anti-competitive stranglehold” over the market. The core allegation centered on the banks’ alleged boycott of three emerging trading platforms that promised to disrupt the traditional dealer-dominated market structure by offering more competitive pricing and enabling direct, transparent trades between institutional investors on the buy-side. This allegedly anticompetitive conduct stands in contrast to how competitive markets typically work.

In a normal competitive environment, when new platforms offer better prices or lower fees, market participants switch to use them. However, if the dominant players collectively refuse to participate or actively discourage clients from using competing platforms, prices remain artificially inflated. The complaint alleged this was precisely what happened in the $1 trillion-plus interest rate swaps market, where the ten banks controlled a significant share of trading volume. While the settlement does not require the banks to admit to wrongdoing, the court’s approval of the settlement and compensation fund effectively validates that plaintiffs presented sufficient evidence of harm to justify the recovery.

What Were the Banks Accused of Doing in the Interest Rate Swaps Market?

How Does the Interest Rate Swaps Market Work and Why Does It Matter?

Interest rate swaps are complex financial derivatives that allow corporations, pension funds, and other institutions to manage exposure to fluctuations in interest rates. In a typical transaction, one party agrees to pay a fixed interest rate on a notional principal amount, while the other agrees to pay a variable (floating) rate. These instruments are essential for corporate treasury management, allowing companies to lock in borrowing costs or adjust their interest rate exposure. The market is enormous and opaque—transactions occur over-the-counter between banks and their clients rather than on regulated exchanges, and pricing has historically been controlled by the major dealer banks who execute both sides of the market.

However, when dealers collectively refuse to participate in transparent competing platforms or coordinate to maintain high bid-ask spreads, institutional investors have limited options and end up paying more than competitive market rates would warrant. The plaintiffs in this case—major institutional investors like pension funds—had limited alternatives to the ten defendant banks if they needed to execute swaps quickly or in large sizes. This is a crucial limitation to understand: while the settlement provides recovery for documented injuries to this specific class, it does not change the underlying structure of the swaps market. Institutional investors must still primarily work through major dealers, and there is no guarantee that competitive dynamics will fundamentally transform post-settlement, particularly since the defendant banks remain dominant market participants with structural advantages.

Interest Rate Swaps Settlement Timeline and FundingCredit Suisse (Earlier)25$ millions (first three), years (last two)Ten Banks (New)46$ millions (first three), years (last two)Total Settlement71$ millions (first three), years (last two)Class Period (Years)16$ millions (first three), years (last two)Final Approval1$ millions (first three), years (last two)Source: Official Settlement Website and Court Filings (U.S. District Court, Southern District of New York, Case 1:16-md-02704-JPO)

Who Can Claim Money From This $46 Million Settlement?

The settlement defines an eligible class as any entity that directly or through an agent entered into interest rate swap transactions in the United States during the class period from January 1, 2008, through June 10, 2024. This includes pension funds, endowments, hedge funds, insurance companies, corporations, and other institutional investors that engaged in these derivative transactions. The most prominent plaintiffs—LACERA and the Chicago Teachers’ Pension Fund—are typical of the class members who alleged they paid unfairly high costs due to the alleged collusion.

To claim settlement proceeds, class members must submit a proof of claim that documents their interest rate swap transactions during the class period. The settlement’s official website (interestrateswapsantitrustlitigation.com) provides the claim form and deadline information. For example, if a corporation executed a $500 million notional amortizing interest rate swap in 2015 with JPMorgan Chase and paid 15 basis points in fees when competitive platforms might have charged 8 basis points, that overpayment could form the basis of a claim allocation. The claims process requires documentation of the transactions, the terms, the counterparties, and the dates—records that most sophisticated institutional investors maintain in their derivative tracking systems.

Who Can Claim Money From This $46 Million Settlement?

How Much Will Settlement Participants Receive?

The $46 million payment from the newly settling defendants combines with the previously settled $25 million from Credit Suisse to create a total settlement fund of $71 million. This fund is not distributed equally to all class members; instead, payments are allocated based on a methodology that considers the size, duration, and nature of each class member’s swap transactions. Claims administrators calculate each claimant’s pro-rata share of the settlement pool based on documented transactions.

To illustrate the comparison: a pension fund that executed $10 billion notional in swaps over the class period would typically receive a larger share than a smaller institutional investor with $500 million in transactions, all else equal. The allocation methodology developed by claims administrators and approved by the court attempts to match each claimant’s proportional injury to the antitrust violation. However, not all documented claimants will receive equal recoveries—some will recover 30-40% of their estimated damages, while others might recover 50-60%, depending on how the settlement fund is distributed. The tradeoff is that certainty through settlement is preferred over the risk of prolonged litigation; a smaller guaranteed recovery now is often worth more than a larger uncertain recovery years from litigation.

What Is the Difference Between Preliminary and Final Court Approval?

The settlement followed a structured approval process that protects class members’ interests. On July 11, 2024, the court granted preliminary approval, which allowed the settlement to proceed toward class notification and objection periods. This stage confirmed that the proposed settlement was within the ballpark of reasonableness and authorized the notice plan. The court then had to approve the claims administration process, allocation methodology, and attorneys’ fees on October 10, 2024, before moving to final approval on July 17, 2025. Final court approval is the stage where the settlement becomes binding and eligible claimants can begin submitting claims and receiving payments.

The deadline for submitting claims is typically set after final approval and published on the official settlement website. A critical warning: missing the claims deadline means forfeiting the right to recover from the settlement, even if you were eligible. Class members have only a limited window—often 12-18 months from final approval—to file their claims. Unlike some other settlements, there are no automatic payments to passive class members; claimants must affirmatively submit proof of their transactions to receive any recovery. The court’s approval of the settlement and claims process establishes the framework, but each institutional investor must actively pursue its share.

What Is the Difference Between Preliminary and Final Court Approval?

What Is the Significance of the June 2024 Settlement Agreement Date?

The June 10, 2024 settlement agreement date is when the defendants and plaintiffs’ counsel reached the negotiated terms that became the basis for court approval. This date also marks the cutoff for the class period—any interest rate swap transactions entered on or before June 10, 2024, are eligible, but subsequent transactions are not. For institutional investors, this date is significant because it provides finality about which of their past transactions qualify for potential recovery.

A pension fund that entered a three-year swap on June 1, 2024, would be included in the eligible class, while one that entered on June 15, 2024, would not. The extended class period stretching back to January 1, 2008, reflects the court’s determination that the alleged collusive behavior extended across the entire 16-year window. This was not a narrow scheme affecting a single year or product, but rather an ongoing pattern alleged to have persisted through multiple market cycles, regulatory changes, and technological developments in the swaps market.

What Happens Now That Final Approval Has Been Granted?

With final court approval granted on July 17, 2025, the settlement enters the claims administration phase. Eligible class members can now submit proofs of claim through the settlement’s claims portal on interestrateswapsantitrustlitigation.com. The claims administrator will review submissions, verify that the transactions fall within the eligible class period and definition, and calculate each claimant’s pro-rata share of the $71 million settlement pool. Payments typically begin rolling out 6-12 months after final approval, once the claims window closes and allocations are finalized.

Looking forward, this settlement addresses past injuries in the swaps market but does not fundamentally restructure how the market operates. The defendant banks remain major players in interest rate swaps trading, and institutional investors will continue to rely on dealer networks for most of their derivative transactions. However, the settlement and the underlying litigation have raised the profile of market structure concerns and may encourage regulators to continue monitoring pricing transparency in OTC derivatives markets. Institutions that participated in the swaps market should review their transaction records to identify eligible claims before the deadline passes.

Frequently Asked Questions

Who specifically can file a claim in this settlement?

Any entity that directly or through an agent entered into U.S. interest rate swap transactions between January 1, 2008, and June 10, 2024. This includes pension funds, endowments, hedge funds, insurance companies, corporations, and other institutional investors. Individual retail investors who did not engage in interest rate swaps cannot claim.

What documentation do I need to file a claim?

You will need proof of your interest rate swap transactions, including: the transaction date, the notional principal amount, the counterparty bank, whether it was a fixed-to-floating or other type of swap, the terms, and the fees or spread paid. Most institutional investors have this information in their derivatives accounting systems.

What is the deadline for filing claims?

The deadline will be published on the official settlement website (interestrateswapsantitrustlitigation.com). Typically, claims must be submitted within 12-18 months of final approval. There are no extensions, so missing the deadline permanently forfeits the right to recover.

How much money will I receive?

Your payment is calculated as a pro-rata share of the $71 million settlement pool based on your documented transactions’ size, duration, and type. Larger transaction volumes typically receive larger settlements, but exact amounts depend on the final claims determination and how many other claims are filed.

Why didn’t the banks admit to wrongdoing in the settlement?

This is standard in antitrust settlements. Defendants typically settle without admitting guilt to minimize legal exposure and avoid additional liability. The court’s approval and the settlement itself signal that plaintiffs presented sufficient evidence of injury to justify compensation.

Where can I file my claim?

Claims are filed through the official settlement website at interestrateswapsantitrustlitigation.com. The claims administrator’s contact information and online portal are available there.


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