GFMA Submits Comments to CESR on Standardisation and Exchange Trading of OTC Derivatives

13 August 2010

The Association for Financial Markets in Europe (AFME) welcomes this consultation paper from the Committee of European Securities Regulators on standardisation and exchange trading of OTC derivatives, and the opportunity to respond. AFME’s Foreign Exchange (FX) Division comprises 21 global FX market participants, collectively representing more than 85% of the FX market.

The FX market is the world’s largest financial market. Effective and efficient exchange of currencies underpins the world’s entire financial system. As many of the current proposals may have a significant impact upon the operation of the global FX market it is vital that the potential consequences of regulatory action are fully understood and that new regulation improves efficiency and reduces risk, not vice versa.

We are aware of the joint response to this paper being submitted by AFME, BBA, ISDA, ASSOSIM and the NSA and are supportive of the views set out in their paper. We have sought here to focus on responses to the points within the consultation paper that are of particular relevance to the FX market.

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