European Swaps Regulation - Comment Letter - CFA Institute - June 25, 2010

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CPSS-IOSCO Considerations for Trade Repositories in OTC Derivatives Markets
June 25, 2010

From the comment letter:

"By their nature, OTC derivatives markets are not subject to formal transparency requirements and thus these financial instruments are relatively opaque in comparison to those instruments primarily traded on regulated exchanges. Enhancing the transparency of OTC derivatives markets is a key step towards strengthening the functioning and resiliency of these markets.

"Investor support for more transparency in OTC derivatives markets is highlighted by the results of a survey of CFA Institute members in October 2009. In that survey, 66% of respondents said that electronic reporting of trades that continue to trade over-the-counter would provide an appropriate level of transparency for investors. We believe that TRs serve as an effective conduit for that electronic reporting."



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