For allocators and portfolio managers
Regulatory, compliance and legal obligation cost sits on operating balance sheets as an unhedged line. Apparently determines and maintains that obligation set; Tomorrow quantifies it into a defined reference and writes it into a perpetual swap two eligible counterparties can take opposite sides of. This page covers mandate fit, what actually drives the exposure, diligence, onboarding and eligibility.
Nothing on this page is investment, legal, tax or accounting advice, an offer or solicitation, or a commitment to quote. No performance, return, yield or correlation figures are published anywhere on this site and none should be inferred. Available only to persons who qualify as eligible contract participants under the Commodity Exchange Act. Either leg can lose money.
01 — Mandate fit
Sleeve
Most commonly an idiosyncratic or alternative-risk sleeve rather than a core book: an exposure underwritten for its own drivers, sized deliberately, and reviewed on its own terms. Funds with insurance-linked, litigation-adjacent or event-driven mandates usually recognise the posture immediately.
Direction
A fund can take the underwriting leg — receiving the negotiated funding payment and paying as the reference rises — or take the other side to hedge obligation-cost exposure it already holds through positions in regulated issuers. Both are supported; both are negotiated per trade.
Liquidity
The position is marked continuously from the reference, so it can be resized, offset or unwound at a mark rather than held to a maturity. Exit still requires a willing counterparty and is subject to the documentation; this is a bilateral market, not a listed one.
Operations
Negotiated master agreement, trade confirmation, credit support terms, periodic funding exchange, continuous marks and a full lifecycle record. If your ops and valuation functions already handle bilateral OTC, they already handle this.
02 — What actually drives it
The reason to look at this exposure is that the thing that moves it is not the thing that moves the rest of your book. That is a statement about mechanism. It is not a statement about realised correlation, and we do not make one.
We publish no performance, backtests, historical series, correlation figures or return expectations, and nothing on this site should be treated as a forecast. Any diversification benefit is an empirical question about your own portfolio, to be answered by your own analysis.
03 — Diligence and onboarding
No step is skipped and eligibility comes first. If a fund is not eligible, or the instrument does not fit, we would rather establish that in week one than in month three.
Entity type, domicile, and eligible contract participant status under the Commodity Exchange Act, together with standard KYC, AML and sanctions checks. This happens before any pricing conversation, and a negative result ends the process.
Your investment and risk teams receive the reference construction: perimeter, obligation classes, observation sources, aggregation method, observation frequency, fallbacks and dispute mechanics. Ask for the parts that would change your model.
How marks are struck and from what, how funding is calculated and exchanged, what the collateral mechanics are, what the record looks like for your administrator and auditor, and how a disputed observation resolves.
Negotiated master agreement and confirmation between you and the counterparty. Your counsel negotiates terms; we do not provide legal advice and do not act as adviser to either party.
You state what you would write or hedge: sectors, jurisdictions, obligation classes, thresholds and size. References are defined against that. An indication assembled from appetite is not a quote and not a commitment.
Execution is bilateral between named counterparties. Thereafter the position marks continuously, funding is exchanged at the stated interval, and the full record — construction, observations, marks, lifecycle events — is available to you for valuation review and audit.
— Origination
You cannot transfer an exposure you cannot state. Apparently states it: it determines what an entity is actually obliged to do, keeps that determination current, and expresses it in a form precise enough to price against. Tomorrow turns that into a contract and a market.
Apparently resolves which regulatory, compliance and legal obligations actually attach to a specific entity — by jurisdiction, activity, licence, and counterparty relationship — and keeps that set current as rules and the entity change. The obligation set is maintained, not snapshotted.
Each obligation is expressed in structured form: what triggers it, what satisfying it requires, what state it is in, and what the defined consequence of non-satisfaction is. Aggregated under a published methodology, that register produces an observable reference level for the entity or a defined cohort.
The reference level is written into contract terms both sides can hold to: what is observed, from what source, at what frequency, how the mark is struck, what happens when an observation is unavailable, and how disputes resolve. A measurement becomes an underlying only once it is defined tightly enough to settle against.
Eligible counterparties take opposite sides of a perpetual swap on that reference. The position is continuously marked, funded periodically between the two legs, collateralised under negotiated documentation, and can be resized, offset, transferred or unwound without waiting for an expiry.
Apparently is a separate data and determination service. It is not a law firm and does not provide legal advice. A reference level built from obligation data is a measurement under a disclosed methodology — not a credit rating, a compliance certification, or a finding that any entity is or is not compliant with any law.
05 — Eligibility and our role
06 — Standing and disclosure
Tell us which leg you would take, which sectors and jurisdictions you would want a reference to cover, and what your risk team would need to see. We will tell you plainly whether the instrument is useful to you yet.
Applying is not an offer to trade and does not create a relationship. Eligibility, including eligible contract participant status, is assessed before any pricing conversation.
