Market Transparency Requirement

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Correspondence

GFMA Guiding Principles for Market Transparency

April 2018  |  Correspondence  |  Press Releases

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 with Other Associations Submit Letter to Multiple Regulators on Global Trade Reporting and Data Harmonization

June 2015  |  Correspondence  |  Press Releases

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

GFMA Submits Comments on the Commission’s Review of Swap Data Recordkeeping and Reporting Requirements

May 2014  |  Correspondence  |  Press Releases

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.

GFMA Submits Comments to the FSB Regarding Study on Approaches to Aggregate OTC Derivatives Data

February 2014  |  Correspondence  |  Press Releases

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.

GFMA Submits Comments to the Malaysian Regulatory Agencies on Trade Repository Reporting Requirement for Derivatives

January 2014  |  Correspondence  |  Press Releases

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 and Other Associations Submit Comments Malaysian Regulators on Trade Repository Reporting Requirement for Derivatives

January 2014  |  Correspondence  |  Press Releases

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.

GFMA Submits Comments to the CSA on Updated Model Rules for Derivatives and Data Reporting

September 2013  |  Correspondence  |  Press Releases

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.

GFMA Submits Comments to the MAS on Reporting of Derivatives Contracts

July 2013  |  Correspondence  |  Press Releases

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.

GFMA Submits Comments to the CFTC on the CME Group Proposal to Require Reporting of All Swaps Cleared with the CME SDR

January 2013  |  Correspondence  |  Press Releases

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). 

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Resources

GFMA One-Pager on LEI Requirements in the SFTR

October 2019  |  Policy Resource  |  Market Transparency Requirement

The Securities Financing Transaction Regulation (SFTR) entered into force on 11 April 2019, with a phased-in compliance period. Compliance with the regulation requires that reporting firms provide their own LEIs as well as the LEIs of their counterparties. This document explains the requirement and the firms impacted.

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News

GFMA Releases Guiding Principles for Market Transparency

16 April 2018   |   News  |  Financial Data

HONG KONG, LONDON and WASHINGTON, 16 April 2018 – The Global Financial Markets Association (GFMA), which represents the common interests of the world’s leading financial and capital market participants, released “Guiding Principles for Market Transparency.” 

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