The fragmentation of trade reporting rules and the lack of a common data set across jurisdictions hinders transparency and global risk monitoring, 存的Priya Kundamal写道.
市场动荡往往会刺激变革. 应对2008年全球金融危机, one of the G20 reforms was to mandate the reporting of over-the-counter (OTC) derivatives transactions to trade repositories, 目标是提高透明度，降低系统性风险. 十多年后, 现在，场外衍生品市场的透明度更高了, vns6060威尼斯城官网可报告数据的重要见解在各个司法管辖区都可以获得.
But this leads to another question: Has the work that has been done so far truly fulfilled the transparency and risk reduction goals originally set forth by the G20? 虽然在地方一级取得了很大进展, more needs to be done to reach the level of transparency and global risk monitoring identified as critical by the G20 over a decade ago. 要到达那里, there must be greater regulatory harmonization of trade reporting rules – specifically to enhance consistency among jurisdictions and facilitate far greater transparency in global markets.
启用一致的数据捕获格式
因为国内的合规要求, G20各辖区的贸易报告采用了不同的数据字段和格式, 导致捕获数据的数量和类型发生变化. 在目前支离破碎的框架下, 整合和分析数据以监控各市场日益增加的风险的能力具有挑战性.
A consistent approach to capturing data based on agreed global standards and data fields would help to enable a truly global reporting framework – leading to the collection of common data sets that can be converted into globally valuable insights. Meaningful data could then be shared between and across markets via regulator-approved cross-border data channels.
“虽然在地方一级取得了很大进展, more needs to be done to reach the level of transparency and global risk monitoring identified as critical by the G20 over a decade ago."
致力于数据协调
Regulators started on their paths to implement common data standards around trade reporting well over a year ago. The Commodity Futures Trading Commission (CFTC) on 20 February 2020 announced its proposed amendments to reporting rules that incorporated critical data elements (CDE) in swap reporting submissions, 引领实现更高程度的同质性和数据协调. Developed by the CPMI-IOSCO working group for the harmonization of key OTC derivatives data elements, CDE旨在实现跨司法管辖区的数据汇总和透明度.
The technical guidance on the CDE does not mandate which CDE regulators should require to be reported in their jurisdictions. It instead details a set of common data elements necessary to understanding derivatives transactions that form the basis of the CDE each jurisdiction could decide to adopt. The important point of the guidance was that when a jurisdiction determines which CDE it requires to be reported, 将使用相同的定义报告CDE, 格式和允许值.
CFTC对掉期报告规则的最终修订已包括采用CDE, 通常被称为CFTC重写, 将于2022年生效. 预计加拿大金融监管机构也将效仿，采用CDE. 大洋彼岸, the European Securities and 3月kets Authority (ESMA) has also included the CDE in its technical standards published under the European 3月ket Infrastructure Regulation (EMIR) Refit, 目前该法案正在获得国会议员的批准.
不幸的是, differences in CDE adoption mean for now firms are still caught in a cycle of updating their reporting systems to meet new rules that do not lead to a common data set across jurisdictions. 这种环境在操作上效率低下，无法实现透明度的目标.
加强区域合作
在亚洲，跨司法管辖区共享数据的能力仍相对未开发. 亚洲各地报告的数据与其他地区报告的数据不同. 话虽如此, there is a steady and gradual shift to decrease the variance in OTC reporting between jurisdictions in Asia. 事实上, regulators in 新加坡和香港 are currently reviewing proposals from their counterparts in the US and Europe and we expect to see the CDE proposal become part of the OTC reporting evolution across Asia as well.
The Australian Securities and Investments Commission (ASIC) has emerged as the first regulator in the region to move on OTC reporting evolution, having released a consultation paper proposing changes to simplify the ASIC Derivative Transaction Rule. 因为CFTC和ESMA并没有完全就CDE的共同方法达成一致, ASIC’s proposal unfortunately is a mix of the ESMA and CFTC approaches – pointing again to the lack of a common data set across jurisdictions.
也就是说, 在澳大利亚, 新加坡和香港, there is an increased level of regional discussions and collaboration on moving towards harmonization of trade reporting requirements. This is evidenced in the focus on driving the adoption of a standardized Unique Transaction Identifier (UTI) – aimed at segueing into greater regulatory harmonization. While the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) have mandated partial adoption of UTI for OTC derivatives reporting, ASIC and the Monetary Authority of Singapore (MAS) have been actively working towards ensuring that the UTI rollout is harmonized across the region.
遵守全球标准将允许清洁实施UTI. 这对拥有全球足迹的公司尤为重要. 以下是CPMI-IOSCO发布的vns6060威尼斯城官网统一UTI的指导, 最终实施的全球标准的采纳很可能发生在澳大利亚, 新加坡和香港.
展望未来12到18个月
While there has been some progress in discussions around regulatory harmonization in the area of trade reporting data, 需要做更多的工作. 不可否认, there may be complications that come with reporting across multiple jurisdictions due to local nuances and data sharing policies. 然而，全球和谐的进程正在稳步前进. 3月ket uncertainty caused by COVID-19 and recent market volatility have highlighted again the need for wider acceptance of data sharing across national boundaries to identify emerging risks and the impact of market activity within and outside of national borders.
鉴于市场的互联性和衍生品交易的全球性, harmonizing trade reporting mandates across jurisdictions will provide regulators around the world with a more complete and holistic view of the OTC derivatives market. 这是未来最大的机遇.
本文最初发表于2021年6月11日的《vns6060威尼斯城官网》.