在2008年金融危机之后, the leaders of the G20 nations took the first step to address the lack of transparency in the over the counter (OTC) derivatives markets. It was universally believed that if regulators and central bankers had timely access to more data on derivatives exposures, 金融危机前后, 潜在的风险本可以更早被发现，解决方案也会更快. 记住这一点, G20 leaders agreed that OTC derivatives transactions should be reported to trade repositories (TRs) to provide greater transparency into the health of the derivatives markets, 从而更好地缓解系统风险.
金融危机发生时，衍生品市场有两点是明确的, 即使没有数据. 第一个, 衍生品市场相互关联，是真正的全球性市场, 这意味着风险可以通过衍生品交易从一个司法管辖区扩散到另一个司法管辖区. 在危机爆发之前，美国资产支持证券结构的风险.S. found its way to portfolios around the world and was then either amplified or reduced using credit default swaps executed between counterparties across jurisdictions. 第二个, there are high concentrations of risk among a relatively small number of participants in the derivatives markets. 这并不是说这些风险管理不力, 但更确切地说，资产负债表的实力和复杂的风险管理责任掌握在少数人手中, and therefore a clearing house or large global dealer often sits on one or both sides of most derivatives transactions.
为什么这两个因素在G20承诺中如此重要? Because any ecosystem designed to achieve the G20’s risk mitigation objective would need to allow for the collection of globally consistent data across jurisdictions, 所以这种风险, 敞口和相互联系可以被理解，而不管风险是在哪里记账的. 也, 虽然收集每一个衍生品交易对手方的数据可能是有用的, the most important part of monitoring systemic risk is collecting data on the clearing houses and dealers that are managing the majority of the risk.
因此, a simplified system that enables the global collection of a standard data set from a smaller set of systematically important players is more pragmatic versus a complex ecosystem that differs from one jurisdiction to the next, 在所需的数据和需要报告的实体方面, 哪些会导致数据无法规范化, 比较或合并.
By 2014, despite calls from the Financial Stability Board (FSB) and others as early as 2010 for global standards and coordination, 很明显，G20承诺的实施是由当地监管要求推动的. 其结果是建立了一个复杂的地方报道网络, falling short of the G20 expectations and expensive to develop and maintain for all reporting market participants and infrastructures.
从那时起，我们为推进二十国集团愿景做了大量工作. 在FSB的指导下, international standard setting bodies the Committee on Payments and Market Infrastructures (CPMI) and the 国际 Organization of Securities Commissions (IOSCO) have worked closely with market participants and regulators globally to propose guidelines for the use of Unique Product Identifiers (UPI), 唯一交易标识符(UTI)和用于交易报告的其他场外关键数据元素(CDE). CPMI-IOSCO还建议治理功能涵盖维护, 监督和实施CDE.
For CDE there were 110 proposed data elements that regulators agreed should be standard and could be used in each jurisdiction to address the issue of jurisdictional differences. CPMI-IOSCO also suggested that CDE should be defined and maintained in the ISO 20022 data dictionary arguing that it will facilitate their inclusion into standardized messages and help participants program CDE into electronic messaging systems thus encouraging a systemic approach to CDE implementation.
一切似乎终于都安排妥当了, 具有明确定义的数据标准, 捕获数据元素的格式化消息和监督实现的治理流程. Each regulator could implement CDE and still ask for additional data elements as an extension to the standards if they felt that the 110 data elements in the proposed guidelines were insufficient for their needs. 然而, 当我们写这个的时候, 有警告信号表明，这些协调努力可能达不到要求, resulting in all industry players upgrading their systems to be compliant with the new requirements only to continue to face an inconsistent approach to global reporting.
两个最大的衍生品监管机构, the European Securities and Markets Authority (ESMA) and the Commodity Futures Trading Commission (CFTC) are currently in various stages of implementing rule changes to adopt CDE. CFTC已经发布了最终的重写规则，而ESMA正处于与该行业磋商的阶段. Having governance and standard definitions in place before the rule rewrites began would have been a more logical sequence. The 法律 Entity Identifier (LEI) 监管 Oversight Committee (ROC) was only recently appointed as the governance body for the implementation of UPI, UTI和CDE以及CDE的ISO 20022信息尚未定义.
此外, an analysis of the ESMA refit proposals and CFTC rewrite has uncovered that the CFTC will be adopting only 78 of the 110 CDE and ESMA only 87. 建议的CDE, only 53 elements are being adopted by both CFTC and ESMA and will be reported in a standardized format across both jurisdictions. 虽然这将推动全球一致报告的方向, the result will be a continuation of the same—a significant number of non-standardized data elements falling short of the FSB’s desired objective of enabling global data aggregation. 如果其他监管机构遵循这种早期模式, 这将导致巨大的变化和很少的回报. 当然，监管机构可能需要的数据超出了普遍认可的元素. 然而, adoption of data elements with even slight differences from the CDE will frustrate the goal of a global standard set of data.
由于tr和市场参与者即将开始修改他们的系统以适应新规则, 现在是时候把事情做好了. It is not too late to review CDE again to create a standard representation of key data elements that all regulators can universally adopt as they rewrite their rules. 现在使用ISO 20022定义标准消息格式还为时不晚, 或者其他标准, 将在新的地方法规中实施. And it is not too late to ensure that the LEI ROC has the resources and processes in place to oversee the regulatory implementation. Otherwise we will be no closer to delivering upon the G20 commitment to create greater transparency in the OTC derivatives market in order to mitigate systemic risk in global financial markets.
本文最初发表于 全球风险监管机构.