Response to CESR's consultation on trade repositories in the European Union
The Group agrees that the establishment of trade repositories could be an important step in the development of tools that allow regulators to have access to more information regarding trading in derivatives markets. In particular we understand their need to be able to obtain a clear understanding of the size of the market, the number of transactions, the size and risk profile of outstanding positions and their potential impact in the event of a default or systemic failure. However, we believe that for any system of trade repositories to be fully effective, a critical part of the exercise will be determining the requirements for the system and processes to be applied in collecting and analysing the information. Material submitted to a TR must be in a standard, consistent format, capable of being interrogated and delivering meaningful and comprehensive reports and analysis. Without this, the ability of regulators to build their understanding of the market will be compromised.
Response to CESR's consultation on trade repositories in the European Union (file pdf - 68 KB)