ARTICLE
24 August 2018

CPMI And IOSCO Seek Comments On Governance Arrangements For Otc Derivatives Data Elements

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The Committee on Payments and Market Infrastructures ("CPMI") and IOSCO outlined potential governance arrangements for OTC derivatives data elements ...
United States Finance and Banking

The Committee on Payments and Market Infrastructures ("CPMI") and IOSCO outlined potential governance arrangements for OTC derivatives data elements other than the Unique Transaction Identifier ("UTI") and the Unique Product Identifier ("UPI") (collectively, "data"). Comments on the consultative report must be submitted by September 27, 2018.

The new consultative report is part of a series. It was commissioned as part of an effort to harmonize data reported to trade repositories to improve transparency, alleviate risk and deter market abuse. CPMI and IOSCO requested comments on the following areas:

  • key criteria for data maintenance and governance;
  • different areas of governance and governance functions (e.g., execution of maintenance functions, oversight functions for critical data elements ("CDE"), and implementation functions, among others);
  • the allocation of governance functions to different bodies and identification of an international governance entity;
  • the assessment of CDE against UTI, UPI and the Legal Entity Identifier; and
  • CPMI and IOSCO's approach to data implementation.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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