European Swaps Regulation - OTC Derivatives Reporting - Comment Letter - Nordic Securities Association - April 14, 2010

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Guidance to Report Transactions on OTC Derivative Instruments - CESR
April 14, 2010

In this comment letter, the Nordic Securities Association (NSA) responds to CESR's consultation paper regarding European OTC derivative instrument transaction reporting. Members of the NSA are the Danish Securities Dealers Association, the Finnish Federation of Financial Services, the Norwegian Securities Dealers Association and the Swedish Securities Dealers Association. Several of the main points that the comment letter discusses includes:

  • The exchange of information between regulatory authorities works well therefore it is time to let the reporting company report to the

regulating authority in the home country or of its choice, in order to decrease the cost of reporting.

  • Swap legs of OTC derivatives based on commodities, rates, and currencies should not be reported, unless one swap leg fulfills the demand for reporting
  • If the OTC derivative has an ISIN or an AII code it should be enough to report that code as it gives all information regarding that instrument, other information should be optional to report
  • What is a "complex derivative" should be clarified by CESR


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