GFMA Submits Comments to the CSA on Updated Model Rules for Derivatives and Data Reporting
6 September 2013
The Global Foreign Exchange Division (GFXD) of GFMA provides comments to the Canadian Securities Administrators (CSA) in response to the CSA Consultation Updated Model Rules - Derivatives: Product Determination and Trade Repositories and Derivatives Data Reporting, CSA Staff Notice 91-302. The GFXD broadly supports the proposed approach outlined in the Updated Model Rules and, specifically, the various amendments made to reflect GFMA's earlier comments on the Draft Model Rules. GFMA offers recommendations limited to key issues which they believe remain, or are newly raised in the CSA Consultation.