The WFC welcomes the public consultation on the “Principles for Financial Market Infrastructures” published in March 2011 by the Committee for Payment and Settlement Systems (CPSS) and the Technical Committee of the International Organization of Securities Commissions (IOSCO).
We make four recommendations to global regulators prior to the finalisation of the Principles:
- The relevance of each principle among the different types of infrastructures should be better defined (for example, differences between CSDs and CCPs);
- The Assessment Methodology should also be subject to public consultation;
- Annex C should be reintegrated in the FMI principles to provide more clarity;
- The Principles should recognise that there are important limitations preventing CSDs to monitor all externalities;
- Finally, the new CPSS-IOSCO Principles should become a true global standard.