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

March 26, 2012

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