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OTC DERIVATIVES - EFAMA response to BCBS – IOSCO consultation report on the initial policy proposals on Risk Mitigation Standards for Non-centrally Cleared Over- the-counter (OTC) Derivatives Background In April 2014, the International Organization of Se- curities Commissions (“IOSCO”) Board approved the mandate of the Working Group on Risk Mitiga- tion Standards for Non-centrally Cleared Over-the- counter (“OTC”) Derivatives. The working group has developed, in consultation with the Basel Com- mittee on Banking Supervision (“BCBS”) and the Committee on Payments and Market Infrastructures (“CPMI”), standards for risk mitigation techniques for non-centrally cleared OTC derivatives. On 1 September 2014, the BCBS - IOSCO con- sultation report was issued. It presents the initial policy proposals emerging from the International Organization of Securities Commissions (“IOSCO”) Working Group on Risk Mitigation Standards for Non-centrally Cleared Over-the-counter (“OTC”) Derivatives. These proposals would establish them in consultation with the BCBS and the CPMI. What’s in there? On 17 October 2014, EFAMA responded to the BCBS-IOSCO consultation report. EFAMA generally considers the initiative to be posi- tive and completely agrees with the points aiming at improving safety and transparency in the over-the- counter derivatives market. Though, EFAMA believes that the proposed stand- ards should not be binding as they are already im- plemented, in Europe, through EMIR.

What’s next? The proposals would establish the risk mitigation standards for non-centrally cleared OTC derivatives.

of this Report. For 8 FSB jurisdictions, self-assess- ments indicated measures have been implemented in all Reform Areas. In 5 jurisdictions (representing 3.36% of MMF markets worldwide), this is because measures were in force in all 8 Reform Areas before 1 October 2012. Based on the public data used by the Review Team this resulted in a coverage of almost 98% of the global MMF industry. THE REPORT IS AVAILABLE HERE. What’s next? ISOSCO will continue to review the implementation progress participating jurisdictions. IOTC DERIVATIVES - IOSCO consults on Post-Trade Transparency in the Credit Default Swaps Market Background Following the global financial crisis of 2007 – 2009, calls were made for reform in the over-the-counter (“OTC”) derivatives market. In June 2010, the G20 Leaders, having committed to an agenda of reform, agreed to accelerate the implementation of meas- ures to improve transparency. The IOSCO consultation paper on mandatory post- trade transparency in the Credit Default Swaps (“CDS”) market comes on the heels of this initia- tive. In producing this consultation paper, IOSCO analysed a large variety of market information and evidence, and consulted a wide range of academic sources in order to analyse the potential impact of post-trade transparency in the CDS market. On 10 November 2014, IOSCO issued a consultation paper in order to inform its final report on post-trade transparency in the CDS market. What’s in there? IOSCO has identified potential benefits and costs to mandatory post-trade transparency in the consulta- tion paper. As a result, IOSCO preliminarily believes that greater post-trade transparency in the CDS market, including making the price and volume of individual transactions publicly available, would be

OTC DERIVATIVES - IOSCO: Report of Key Preliminary Findings to the G20 Leader’s Summit Background In September 2013, the G20 Leaders in St Pe- tersburg invited the International Organisation of Securities Commissions (“IOSCO”) to review and report on progress relating to money market funds (“MMFs”) regulatory reforms in late 2014. Following the G20 Leader’s Request, IOSCO con- sented to conducting a review consisting of an im- plementation progress report about the current reg- ulatory reform efforts of participating jurisdictions. What’s in there? The report was published in November 2014 and identifies progress in adopting legislation, regula- tion and other policies in relation to MMFs in the following areas: « Scope of the regulatory reform - explicit definition of MMFs in regulation and appropriate inclusion of other investment products presenting features and investment objectives similar to MMFs; « Limitations to the types of assets of, and risks tak- en by, MMFs; « Valuation practices of MMFs - addressing specific valuation issues for MMFs and their portfolios; « Liquidity management for MMFs - aimed at en- suring MMFs maintain adequate liquidity resourc- es in normal business conditions as well as in stressed market conditions; « MMFs that offer a stable Net Asset Value (NAV) - addressing the risks and issues which may affect the stability of MMFs that offer a stable NAV;

« Use of ratings by the MMF industry;

« Disclosure to investors; and

« Repos - MMF practices in relation to repurchase agreement transactions.

23 FSB members (representing almost 83% of MMF markets worldwide) and 7 non-FSB members (representing almost 15% of MMF markets world- wide) provided the responses on which this Report is based. One FSB member (Indonesia) had not provided a response at the time of the preparation

FOR DETAILS ON THE PROVIDED ANSWERS: THE EFAMA RESPONSE IS AVAILABLE HERE

THE BCBS-IOSCO CONSULTATION REPORT IS AVAILABLE HERE

Scanning - December 2014 - page 9