2015年-FSB全球金融稳定委员会_Public_responses_to_the_November_2014_Proposed_Standards_and_Processes_for_Global_Securities_Financing_Data_Collection_and_Aggregation_5页_129kb

AMUNDI'S SUMMARY OF RESPONSE TO FSB'S CONSULTATION ON SECURITIES FINANCING DATA COLLECTION AND AGGREGATION

Core Content

Amundi, a leading global asset manager with AUM of nearly €850 billion, has responded to the FSB's consultation on the standards and processes for global securities financing data collection and aggregation. The company emphasizes the importance of financial stability and the need for data to be used solely for monitoring systemic risk, rather than as a tool for introducing new regulatory requirements.

Amundi highlights that the asset management industry, particularly funds like UCITS and AIFs, is highly regulated and should not be subject to the same reporting obligations as entities that use securities financing for leverage. The company advocates for the exclusion of non-leveraged funds from SFT reporting, arguing that such reporting would be redundant and burdensome.

Main Points and Key Information

1. Regulatory Context and Industry Position

• Amundi is a major asset manager with a strong presence in 30 countries and a wide range of products across all asset classes and currencies.
• The company offers savings solutions to over 100 million retail clients and designs institutional products tailored to specific risk profiles.
• Asset managers (excluding hedge funds) rarely use repos or borrow securities, and the term "Securities Financing Transactions" (SFT) is misleading in the context of asset management.

2. Position on SFT Reporting

• Amundi believes that only Hedge Funds should be included in SFT reporting due to their use of leverage.
• UCITS and non-leveraged AIFs should be exempt from SFT reporting, as they do not engage in leveraged activities.
• The company is concerned that adding new reporting requirements for SFTs could increase costs and reduce returns for investors.

3. Data Granularity and Definitions

• Amundi questions the granularity of data elements in the proposed reporting framework, especially the classification of funds in field 3.3 of Table 3.
• The company suggests that the distinction between leveraged and non-leveraged funds is more relevant than the current classification.
• Amundi also raises concerns about the use of external ratings (e.g., from CRAs) in defining investment-grade bonds, arguing that regulators should move away from such references.

4. Collateral and Market Segment Classification

• Amundi believes that reporting on collateral reuse and collateral type is necessary but should be handled carefully to avoid unnecessary complexity.
• The market segment classifications (trading and clearing) should reflect the structural features of the repo and securities lending markets more accurately.

5. Reporting Structure and Efficiency

• Amundi supports entity-level reporting over transaction-level reporting to better track systemic risk.
• The company advocates for the use of thresholds and summary tables to reduce reporting burdens and ensure data relevance.
• Amundi emphasizes the need for consistency in global data collection and the importance of data quality over quantity.

Recommendations

Q3-1: Data Architecture

• Amundi believes the data architecture should be entity-level and not transaction-based.
• The FSB should ensure that exemptions (e.g., for UCITS and non-leveraged AIFs) are standardized across jurisdictions.

Q3-2: Reducing Reporting Burden

• Suggested methods include the use of thresholds, regulatory entity focus, one-sided reporting, and summary tables.
• Amundi warns against the cumulative addition of reporting requirements, as it may lead to inefficiencies and increased costs.

Q3-3: Double-Counting Measures

• Amundi supports the measures to minimize double-counting, but stresses the importance of practical implementation.

Q3-4: Confidentiality Issues

• Amundi raises concerns about confidentiality and suggests that existing reporting fields should be assessed to avoid redundant data collection.

Q6-1 to Q6-4: Extension of Data Elements and Pilot Exercise

• Amundi supports the idea of a pilot exercise before implementing the new reporting framework.
• The company suggests that aggregation levels and publication frequency should be tailored to the type of transaction (repo, securities lending, margin lending).
• Amundi recommends that the FSB take the lead in determining the level of granularity and classification standards for data elements.

Conclusion

Amundi's response underscores the need for practical, consistent, and focused data collection that supports financial stability monitoring without imposing undue regulatory burdens on the asset management industry. The company calls for standardization of exemptions and classifications at the FSB level, and emphasizes the importance of data quality and efficiency in regulatory reporting.