International Swaps Regulation - Comment Letter - Markit - September 19, 2011

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CFTC and SEC Staff Roundtable on International Issues
September 19, 2011

Summary of recommendations from the comment letter:

  1. "ensure that important aspects of real-time reporting regimes, including the data to be reported, are in harmony with those required by foreign regulators;
  2. permit market participants to use third party providers that operate internationally for valuation and scenario analysis services because these entities would use internationally valid standards and inputs;
  3. permit market participants to delegate initial margin (“IM”) calculation to third parties that operate internationally because they could provide would-be counterparties with estimates of IM based on different national requirements;
  4. ensure that any unique identifier systems used for reporting purposes are used consistently across the globe in order to enable data to be properly aggregated, and that the creation of such systems is open to input from all stakeholders; and
  5. permit market participants to obtain a legal entity identifier (“LEI”) through a self-registration process or from a counterparty who would act as their agent in the registration process."


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