To improve regulatory outcomes and deliver on the benefit of reforms, GFMA calls on global financial regulators to agree to principles to design regulatory cooperation arrangement s to develop consistent regulatory regimes and supervisory practices. GFMA encourages global policymakers to establish regulatory cooperation arrangement s that are : i Forward-looking; ii Enhance cross-border investment and market integrity; iii Supportive of similar outcomes; iv Predictable; v Transparent; vi Evidence-based; vii Proportionate; viii Enhance market certainty; ix Strengthen supervisory coordination; and x Supportive of conflict mitigation.
Type your message here
We encourage global policymakers to adopt these principles for regulatory cooperation arrangements, which we believe will improve long-term market integrity, efficiency, liquidity, and resilience by minimizing the risk of fragmentation and the adverse effect it has on global economic growth. 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. 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.
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. The level of transparency and timing for reporting should be appropriately calibrated based on regulatory intent, market structure, and liquidity profiles of specific assets.
An effective transparency framework is based on consultation with all market participants and a cost-benefit analysis. See: Full Press Release here. See: Press Release.
- Subscribe to our newsletter!
- Navigation menu?
- gunbot rsi strategy?
- best forex signal indicator free download!
- ACI FOREX DENMARK - ACI Forex Finland ry!
- td ameritrade currency options;
While supportive of the broad goals of the BMR to provide a harmonized regulatory framework for non-significant benchmarks in the EU, comments emphasized the need for greater proportionality in several aspects of the draft guidelines. The trades recommended that ESMA should eliminate or reduce some of the requirements of the draft guidelines, to achieve a more proportionate, principles-based and balanced approach, particularly where the draft guidelines covers obligations similar to those which are not applicable to non-significant benchmark under the BMR.
The letter emphasizes the need for enhanced supervisory standards to support financial stability, market efficiency, and end-user choice. Brexit is an event of such magnitude that it will affect almost all dimensions of the global economy, including financial services, in some way.
Please note: the PDF download includes the consultation paper with the GFXD response to each question; this is the mandated consultation format. Also, see: Application of position limits to non-commodity contracts and to securitised commodity derivatives. GFMA provided comments to regulators on a request for postponement of margin requirements for uncleared swaps for phase 1 covered swap entities. GFMA provides letter to multiple regulators accompanying a copy of a report commissioned from Oliver Wyman, which analyzes the interaction, coherence, and overall calibration of post crisis regulatory reform measures agreed upon, or under active consideration, by the Basel Committee on Banking Supervision BCBS.
The full report is available here. We encourage a dialogue over industry concerns over the recent proliferation of penetration testing regulations and guidance from regulators, SROs, and government agencies around the world, and the downstream impact to the financial services industry. The proposal is very expansive and could require massive amounts of effective consolidation if read broadly.
We do not believe step-in risk is a material issue at this point and suggest the Basel Committee should forego implementing new rules in this area. We also raise significant concerns with the lack of clarity and expansive breadth of the proposal. See also: Identification and measurement of step-in risk - consultative document. See: Haircut floors for non-centrally cleared securities financing transactions - consultative document.
Guideline ACI E | Test (Assessment) | Futures Contract
The associations strongly agree there is a need for a global, standardized approach for the regulatory reporting of branches and branch activity and believe the LEI system provides a good operational structure for this purpose. While the associations support new guidance for a branch identifier, they have several concerns with the approach proposed by the ROC and make recommendations for addressing those concerns in the letter.
The objective of this initiative was to investigate the aggregate impact of the proposed FRTB framework and to provide data-driven feedback to the policymakers for further consideration. We believe this supplementary qualitative information provides useful context for the estimates of an industry-wide impact of the current FRTB proposals.
GFMA CWG urges the CFTC to avoid the anomalies and associated impacts to liquidity and the proper functioning of the market that are likely to arise as a result of the Proposed Rule's failure to appropriately address dealers' net risk positions taken to hedge commitments under commodity index contracts. While the current FX industry best practice is to document transactions with their counterparties in Exempt FX Products, it is not universal for the reasons described in this letter.
Because of the significant number of institutions that trade Exempt FX Products that are not covered by Compliant Documentation, the lack of awareness that the STRD Rule applied to Exempt FX Products, and the lengthy negotiations necessary to enter into new documentation because such documentation does not exist, or to amend existing documentation to bring Exempt FX Products within scope , many institutions will be unable to satisfy the STRD Rule by July 1, Securities Act of Regulation AB.
The additional time will allow adequate assessment of impact on products and markets to ensure that this is aligned with the overall public policy goals. The Associations support the work of the Committee and specifically of the Task Force for Simplicity and Comparability TFSC aimed at conducting a comprehensive review of the capital framework and its overall calibration and taking stock of the multiple changes thereto in the course of the past 5 years.
The Joint Associations welcome the opportunity to contribute to the discussion on capital floors. Related: The December Consultative Document - Capital floors: the design of a framework based on standardised approaches - consultative document. GFMA brings together three of the world's leading financial trade associations to address the increasingly important global regulatory agenda and to promote coordinated advocacy efforts.
GFMA wrote a letter to all G20 Finance Ministers recommending improved coordination in the implementation of reforms in different jurisdictions. GFMA believes international coordination efforts can be strengthened further and that more needs to be done at the G20 level to ensure individual jurisdictions honor their global commitments in domestic policy implementation.
All Instruments
GFMA provides comments to the Department of Energy and Climate Change's Consultation on strengthening the regulation of wholesale energy markets through new criminal offences. The groups continue to continue to strongly support the comments raised in the prior letter, including the equities-related comments. Therefore, none of the points outlined in the supplemental letter should be construed to supersede or override any of our original requested alternative treatments for equities or non-equities instruments.
The groups remain concerned that the current proposals will not meet the Committee's stated objective of comparability, resulting instead in capital requirements that are neither comparable among calculation methods nor proportionate to risks. It is essential that the timetable for finalisation of the proposed framework is extended to address those shortcomings. Additional work should be undertaken to refine the calibration of the proposed framework and especially to improve the consistency of results between the internal ratings-based approach IRBA , the external ratings-based approach ERBA and the standardised approach SA.
This should include gathering additional, more granular data and undertaking further analysis beyond what was provided in the QIS. In particular, we would recommend conducting analysis of data grouped by the market-defined asset classes of the underlying exposures rather than according to the regulatory exposure categories. Further consideration should also be given to additional analytical work provided by the industry and referred to in the Joint Associations' comment letter dated 24 March Comment Letter.
These data are limited as explained in the Report, and the Report should be read and understood in that context. It is especially important to note that the Report does not advocate or support a particular calibration method or outcome, and in particular we do not intend that any of the implied p-values set out in the report should be used to calibrate the revised framework. Rather, the Report reveals a number of results that we respectfully ask the Committee to consider as they continue to work on the proposed revisions. GFMA believe that an outcomes-focused recognition approach, where regulators are able to rely on the oversight of other regimes adhering to the same general regulatory objectives, would serve to avoid many of the above referenced issues.
GFMA welcomes the development of these Principles by IOSCO as a step towards ensuring that key oil market benchmarks are subject to robust, consistent, transparent and sound practices. While supportive of the progress to date, GFMA considers that more could be done to ensure market integrity.
These codes must be sufficiently robust to ensure transparency of methodology and price assessment, and also to strengthen governance oversight, internal controls including identification of trade anomalies and verification by third parties and management of conflicts of interest.
In addition to addressing the specific questions in the consultation, the groups take the opportunity to raise some high level points that we feel are important in the wider context of the reporting regime under REMIT. Because transactions in FX spot, alongside FX swaps and FX forwards, are integral to the global payment system, international trade, cross-border activity and monetary policy, it is essential that the smooth functioning of the FX market not be disrupted. For these reasons, we wish to emphasize the importance in ensuring that the regulatory treatment of FX products within the European Union — and across multiple jurisdictions globally — is consistent.
The industry believes that the Sensitivity Based Approach SBA , as put forward by the BCBS, constitutes a significant improvement to the previous version of the methodology and is in line with industry recommendations on leveraging upon existing validated risk metrics to calculate the market risk capital requirements. The Advanced Cash Flow Approach ACFA methodology, on the other hand, is not computationally supported by existing infrastructure, since cash flow data are not captured at the trade level.
As a result, industry members would require extensive resources to adhere to currently proposed regulatory timelines whilst achieving little in terms of enhancing the risk sensitivity of output metrics. This would be particularly onerous for smaller organizations. GFMA requests that the Committee engage in a similar way with the industry in this, relatively new, context of the NSFR in order to achieve a treatment of high quality securitisation that accurately recognises its strong credit performance through and since the financial crisis as well as its benefits as a self-liquidating funding tool for the real economy.
As part of the clarification and as an interim step, the GFXD asks the European Commission to consider an FX transaction that is entered into solely to effect the purchase or sale of a foreign security FX Security Conversions — to be a bona fide spot transaction in situations where the settlement period is greater than two days. The groups welcome the development of a simpler and more straightforward hierarchy of approaches, some reduction of risk weights for higher credit quality exposures, including reduction of the risk weight floor, recognition of credit protection provided by excess spread, preservation of existing flexibility in application of the Internal Ratings-Based Approach IRBA , preservation of the Internal Assessments Approach IAA , and requiring one rather than two qualifying credit ratings for application of the External Ratings-Based Approach ERBA.
However, the groups believe that the proposed capital requirements for securitisation exposures, especially for higher quality exposures and for medium-term and longer-maturity transactions, remain much higher than justified by historical loss incidence in most asset classes, by comparison with other methods of finance or in relation to the capital requirements of the underlying asset pools. These excessive capital requirements will discourage banks from investing in or otherwise acquiring exposure to securitisation transactions.
The groups recommend specific changes to certain of the modelling assumptions and parameters used in formulating and calibrating the approaches, as well as changes to the operating conditions for certain approaches and to the risk weight floor and capital cap provisions. GFMA and other associations provide comments to the Basel Committee on Banking Supervision BCBS requesting clarification on how the final leverage ratio framework rules should be interpreted at this stage, so as to ensure that they are transposed correctly and consistently in national and regional implementation measures, without unintentional adverse impacts on the markets.
GFXD believes that, if granted, the no-action relief NAR requested in this correspondence would largely mitigate the legal uncertainties that have contributed to the continued reluctance on the part of market participants to trade Non-Cleared Swaps on SEFs, and would help foster an orderly transition to the SEF marketplace for Non-Cleared Swaps as the Interdivisional Working Group completes its work. The presentation details key components of the approach, benefits, shared values and commonality of objectives, and regulatory principles.
This letter addresses important developments related to implementation and global consistency of the G20s regulatory reform agenda which may risk divergence from consistent implemention. 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. 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.
FlexAdvantage Blog
The groups offer a few brief comments on the Draft Recommendation as well respond to the three questions included in the paper. The groups believe the Consulative Document is a significant step in the right direction and believe that the proposed non-internal model method NIMM framework has great potential. However, the industry feels an articulation of supervisory standards for the definition of effective notional that will allow firms to reliably and consistently apply NIMM to the vast majority of derivative structures is important.
We urge the Basel Committee to articulate these standards to help ensure global consistency and a level playing field, facilitating an effective application of NIMM. This letter starts with a reiteration of the major themes the industry raised at the workshop, followed by detailed discussions of our comments on the Phases 2 and 3 templates. The Associations commend the BCBS for undertaking another consultation on these proposals and desire to provide meaningful input to ensure a viable capital framework is adopted. This response focuses on elements of the consultative document that stand to motivate and influence the expansion of central clearing.
They also believe the proposal fails to provide incentives for CCPs to invest in the improvement of their risk systems and methodologies and discourages fundamental CCP risk practices, notably the intended function of the default fund. Effective recovery, continuity and resolution mechanisms for FMIs are critical to the efficient operation and sustainability of the financial markets.