MFA Submits Comments to the Monetary Authority of Singapore on Proposed Regulations on OTC Derivatives

March 26, 2012

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Topics: Monetary Authority of Singapore MAS, OTC derivatives, over-the-counter derivatives, Consultation Paper on Proposed Regulation of OTC Derivatives, G20, OTC derivatives market, systemic risk, efficient capital flows, mandary clearing, clearing, bilateral market, risk management, derivatives transactions, trading mandate, liquid and standardized transactions, client access to clearing, clearing arrangements, margin methodologies, straight-through processing, central clearing, Commodity Futures Trading Commission, CFTC, Gary Gensler, Securities and Exchange Commission, Mary Schapiro, market participants, central counterparty, CCP, average notional value, clearing threshold, buy-side clearing, U.S. Federal Reserve Bank of New York, Dodd-Frank Wall Street Reform and Consumer Protection Act, Dodd-Frank Act, backloading, Financial Stability Board, FSB, international harmonization of regulations, swaps, European Union, EU, European Commission, ESMA, legal entity identifiers, confidentiality, transaction data, counterparty identification, customized and proprietary investment strategies, intellectual property, International Organization of Securities Commissions, IOSCO, foreign regulator, financial entities, non-financial entities, Singapore, Form PF, margin requirements, netting, trading costs, aggregate counterparty credit risk, settlement risk, commercial banks, dealers, money changers, registered insurers, non-centrally cleared derivatives transactions, margin determinations, liquidation horizons, fragmentation of liquidity, clearing house, counterparty risk, recognized clearing houses, clearing facilities, real-time processing, barriers to entry, non-dealer client representation, risk committees, G20 commitments, regulatory regime, duplicative regulation, U.S. Senate Committee on Agriculture Nutrition and Forestry, trade repositories, Securities and Futures Commission, Honk Kong Monetary Authority,
From: MFA, Stuart Kaswell

To:

Monetary Authority of Singapore

MFA submitted a comment letter to the Monetary Authority of Singapore (MAS) in response to its Consultation Paper on Proposed Regulation of OTC Derivatives. In our letter, among other things, MFA requested that MAS: 1) require mandatory access to clearing for all eligible market participants that wish to clear on a voluntary basis; 2) not apply the clearing mandate retroactively to existing contracts (i.e., no backloading of trades); 3) protect the confidentiality and proprietary nature of all information submitted to trade repositories in response to the reporting mandate; 4) ensure that any imposed margin requirements permit legally enforceable netting, allow the use of a variety of margining approaches that are transparent and consistent, and include liquidation horizons that are consistent with the related cleared products; and 5) continue to coordinate and harmonize the proposals in the consultation paper with the proposed regulatory regimes in other jurisdictions.

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