2014年-FSB全球金融稳定委员会_Public_responses_to_February_2014_consultative_document_Feasibility_Study_on_Approaches_to_Aggregate_OTC_Derivatives_Trade_Repository_Data_9页_407kb

AFR Comment on FSB Derivatives Data Aggregation Study

Core Content

Americans for Financial Reform (AFR) has submitted comments on the Financial Stability Board's (FSB) feasibility study regarding the aggregation of over-the-counter (OTC) derivatives trade repository data. AFR is a coalition of over 200 American civil society organizations, including labor, consumer, civil rights, investor, retiree, community, and faith-based groups. Their primary concern is the lack of transparency and the inability of regulators to effectively monitor financial risk exposures, particularly in OTC derivatives markets, which contributed to the global financial crisis.

Main Points

• Transparency and Risk Monitoring: AFR emphasizes that improving transparency in financial risk exposures is essential for effective financial reform. The inability to aggregate and monitor these exposures undermines the reliability of financial oversight.

• Slow Progress: Despite the importance of the issue, progress on aggregating derivatives data has been slow. U.S. regulators cannot even aggregate data within the country's own dealers and trade repositories. Globally, the challenge is even greater with multiple jurisdictions and repositories.

• Rejection of Option 3: AFR argues that the current system (Option 3), where national regulators work with trade repositories and share data among themselves, is inadequate and must be rejected. It hinders the development of a more robust and transparent system.

• Options 1 and 2: AFR acknowledges that the FSB must choose between Option 1 (centralized data storage) and Option 2 (virtual data access). Both options face similar technical challenges in data aggregation, but differ in data availability. Option 2 requires reliable remote access, which may be difficult to ensure.

• Governance Structure: AFR suggests that a single public entity should be established to oversee the aggregation process, with clear lines of authority and responsibility. They prefer a structure similar to the "international data hub" over a multi-tiered public-private partnership.

• Prioritizing Reliability and Speed: AFR urges the FSB to prioritize the implementation of a reliable and efficient aggregation mechanism. They recommend continued exploration of both options with IT experts to ensure a sound decision.

Key Information

• AFR Membership: AFR includes major labor, consumer, civil rights, investor, retiree, community, and faith-based organizations.
• Partners: AFR has a wide range of partners, including AARP, AFL-CIO, AFSCME, Alliance For Justice, and many state and local organizations.
• State and Local Partners: AFR has numerous state and local partners, such as Alaska PIRG, Arizona PIRG, California PIRG, and others, working on various aspects of financial reform.
• Small Businesses: Some small business organizations, such as Blu, Bowden-Gill Environmental, and Community MedPAC, are also associated with AFR.

Conclusion

AFR calls for a more centralized and reliable approach to aggregating OTC derivatives data, arguing that the current system is insufficient. They advocate for a governance structure that ensures clarity and accountability, and for a rapid implementation of a robust data aggregation mechanism. AFR believes that continued exploration of both Option 1 and Option 2 with IT experts is necessary to determine the most effective solution.