GFMA published Guiding Principles for Market Transparency.

Increasingly, regulators are developing public transparency requirements across markets and jurisdictions, which highlights differing policy objectives for rules and the need for shared global principles. Market transparency requirements should support specific policy objectives, consider the fundamental structural differences between markets and among asset classes, and provide meaningful and useful information to market participants while doing no harm to market integrity, liquidity, efficiency and resilience.  Fundamental structural differences between markets, including participants and their needs, preclude a “one-size-fits-all” approach. 

GFMA encourages policymakers and regulators to design market transparency frameworks in line with the following principles:

I.             Transparency to regulators should be timely, consistent and appropriate to fulfil market surveillance duties and to support market integrity.

II.            Public market transparency requirements should support the provision of liquidity for price formation and risk management, while doing no harm to market integrity, liquidity, efficiency and resilience.

III.           The level of transparency and timing for reporting should be appropriately calibrated based on regulatory intent, market structure, and liquidity profiles of specific assets.

IV.          An effective transparency framework is based on consultation with all market participants and a cost-benefit analysis.

V.            The market’s ability to implement requirements, including on a cross-border basis, if appropriate, is critical.

See: Full Press Release here.

GFMA provides response to IOSCO regarding consultation on regulatory reporting and transparency in the secondary corporate bond markets.

GFMA, SIFMA and the Asset Management Group of SIFMA (SIFMA AMG), The Australian Financial Market Association (AFMA), the Alternative Investment Management Association (AIMA), the British Bankers Association (BBA), the German Investment Funds Association (BVI), the European Fund and Asset Management Association (EFAMA), the Futures Industry Association (FIA Global), the Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association (GFMA), the International Swaps and Derivatives Association (ISDA), the Managed Funds Association (MFA) and The Investment Association provide comments supporting key principles to improve global trade reporting and data harmonization. 

This letter was sent to:

ASIC
BIS
Canadian Securities Administrators
CFTC
CPMI
EBA
ECB
EC
ESMA
FSB
FINMA
HKMA
IOSCO
JFSA
MAS
OFR
Reserve Bank of Australia
SEC

The Global Foreign Exchange Divisions (GFXD) of GFMA provides comment on the Commission's Review of Swap Data Recordkeeping and Reporting Requirements.

The GFXD recommends that the CFTC considers the implications, financial and otherwise, of any recommendations that the CFTC may make to its existing part 45 requirements as a result of this Request for Comment. We also urge the CFTC to align any recommended changes to those recently recommended by the GFXD in our response to the FSB's Consultation Paper regarding the aggregation of OTC derivatives data.

The Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association (GFMA) provides comments to the Financial Stability Board - Aggregation Feasibility Study Group of the Bank for International Settlements regarding the Consultation Paper on the Feasibility study on approaches to aggregate OTC derivatives data issued by the Financial Stability Board (FSB) on February 4th, 2014.

The Global Foreign Exchange Division (GFXD) of GFMA provides comments to the Securities Commission Malaysia (SC), Bank Negara Malaysia (BNM) and Perbadanan Insurans Deposit Malaysia (PIDM) (collectively the Regulatory Agencies) on the Joint Public Consultation Paper on Trade Repository Reporting Requirement for Over-the-Counter Derivatives.

Many of the current legislative and regulatory reforms will have a significant impact upon the operation of the global FX market and GFXD feels it is vital that the potential consequences are fully understood and that new regulation improves efficiency and reduces risk, not vice versa.

GFXD is supportive of the approach outlined in the joint consultation paper and provide specific comments with respect to the requirements and your questions. In addition, GFXD particularly welcomes the Regulatory Agencies' to harmonise reporting requirements under the regime with those that will apply internationally.

GFMA, as part of the The LEI Trade Association Group, a coalition of financial services firms and trade associations, provides comments to Securities Commission Malaysia (SC), Bank Negara Malaysia (the Bank), and Perbadanan Insurans Deposit Malaysia (PIDM) (Regulatory Agencies) on their Joint Public Consultation Paper: Trade Repository Reporting Requirement for Over-the-Counter Derivatives , NO. 1/2013, November 20, 2013.

The Associations strongly encourage the Regulatory Agencies to reconsider the use of the SWIFT code or company registration number for identifying Parties in trade reporting. Instead, the groups respectfully propose the adoption of the legal entity identifiers (LEIs) that are available through the Global Legal Entity Identification System (GLEIS) towards this purpose. The GLEIS, developed under the auspices of the Financial Stability Board (FSB) and endorsed by the G20, is aimed at achieving a unique, unified global system of identification of parties to financial transactions.

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.

The Global Foreign Exchange Division (GFXD) of GFMA provides comments to the Monetary Authority of Singapore (MAS) on the Consultation Paper on Draft Regulations Pursuant to the Securities and Futures Act (SFA) for Reporting of Derivatives Contracts, P006-2013-June 2013.  The GFXD is supportive of the approach outlined in the consultation paper and provide specific comments with respect to the requirements and the questions posed by the MAS. The GFXD  particularly welcomes the MAS's efforts to harmonise reporting requirements under the regime with those that will apply internationally.

The Global Foreign Exchange Division (GFXD) of GFMA provides comments to the U.S. Commodity and Futures Trading Commission (CFTC) on on the proposal made by the Chicago Mercantile Exchange Inc. (CME) in its amended submission # 12-391R dated December 6, 2012, which requests the CFTC to approve of a new Chapter 10 and Rule 1001 (the Proposed Rule) of the CME's Swap Data Repository (SDR) rulebook.

GFMA believes that the CFTC should not approve the Proposed Rule for multiple reasons, including that the Proposed Rule, which would require all swaps cleared with the CME to be reported to the CME's SDR, violates the “fair and open access” principle of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

GFMA emphasizes that the concerns raised in this letter are not exclusive to the CME and the Proposed Rule, but apply generally to any designated clearing organization (DCO) that seeks to require all swaps cleared with it to be reported to a specific swap data repository (SDR). 

GFMA provides comments to the European Commission (EC) on the EC Stakeholder Consultation on the implementation of a data and transaction reporting framework for wholesale energy markets.  In July, GFMA sent a letter to the Agency for the Cooperation of Energy Regulators (ACER) regarding its REMIT Data Collection Public Consultation Paper.  In this correspondence, GFMA responds to the EC's additional questions and offers details on where GFMA's position changed since July.

GFMA provides comments to the Commodity Futures Trading Commission (CFTC) on real-time public reporting of swap transaction data, RIN 3038-AD08 – 17 CFR Part 43. In the proposed rulemaking, the CFTC asks for specific data and analysis to support the block trades proposal. At this time, it is difficult to provide such statistical analysis given that there are no central bodies responsible for collecting sufficiently granular detail – an issue that swap data repositories (SDRs) are in part intended to address. GFXD therefore advocates an approach that allows the CFTC flexibly to assess the appropriate methodologies for determining swap categories, block sizes and cap sizes.

The coalition of financial services firms and trade associations (Trade Associations) provides comments to IOSCO on their August 2011 IOSCO-CPSS Consultation Report on OTC derivatives data reporting and aggregation requirements.

The Trade Associations support the IOSCO-CPSS position that “a system of legal entity identifiers (LEIs”) would be an essential tool for the aggregation of OTC derivatives”.

The Global FX Division provides comments to the Bank for International Settlements (BIS) and the International Organisation of Securities Commissions (IOSCO) on the Consultative Report on OTC derivatives data reporting and aggregation requirements, Aug 2011.  The Global FX Division notes the selection of a preferred partner for trade repository services arises from the general preference of the industry for the use of global trade repositories, rather than multiple, fragmented local repositories. This is because they provide the chief benefits of enhanced regulatory oversight and efficiency of data capture. This is particularly the case for the FX market which is characterised by vastly higher number of transactions and participants when compared to other asset classes given its position as the basis of the global payments system.

GFMA provides comments to the U.S. Commodity Futures Trading Commission (CFTC) on swap data recordkeeping and reporting requirements for pre-enactment and transition swaps (also known as historic swaps), as issued by the Commission to implement provisions of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  Members of the Global Foreign Exchange Division (GFXD) are committed to supporting the establishing of an single data repository (SDR) to accommodate the foreign exchange asset class.

The Global Foriegn Exchange Division (GFXD) of GFMA provides comments to the Commodity Futures Trading Commission (CFTC) on swap data repositories, swap data recordkeeping and reporting requirements,  real-time public reporting of swap transaction data, RIN 3038-AD20 – 17-CFR Part 49, RIN 3038-AD19 – 17-CFR Part 45, RIN 3038-AD08 – 17 CFR Part 43.  This letter is supplemental to GFXD's previous submissions on the proposed swap data repository (SDR) rules and is intended to clarify and further explain certain comments.
 

The Association for Financial Markets in Europe (AFME) welcomes the Committee on European Securities Regulators' consultation paper on transaction reporting on OTC derivatives and extension of the scope of transaction reporting obligations, 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, ISDA and& ASSOSIM 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.