ARTICLE
1 November 2016

CPMI And IOSCO Request Comments On OTC Derivatives Transactions Data Elements

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Cadwalader, Wickersham & Taft LLP

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The Committee on Payments and Market Infrastructures and IOSCO requested comments on a consultative report that concerns the development of definitions and guidance for data elements to be used in reporting over-the-counter derivatives transactions.
United States Finance and Banking

The Committee on Payments and Market Infrastructures and IOSCO requested comments on a consultative report that concerns the development of definitions and guidance for data elements to be used in reporting over-the-counter derivatives transactions. The report focuses on the second of three batches of critical data elements that (i) represent dates, times and identifiers (other than unique product identifiers and unique transaction identifiers) or (ii) pertain to cashflows.

CPMI and IOSCO ask commenters to consider whether the proposed definitions for each critical data element:

  • provide enough guidance for authorities to support consistent data reporting and meaningful global data aggregation;
  • appropriately reflect different market practices on a global level; and
  • appropriately reflect current industry standards that already may be in use globally.

Comments on the consultative report must be submitted by November 30, 2016.

Commentary / Steven Lofchie

Before they ask the OTC derivatives markets to spend tremendous amounts of money collecting and reporting this data, regulators should consider whether the end result will be useful. The government's actual need for much of the data it requires is not obvious.

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