WFC comments on CPSS-IOSCO assessment and disclosure

The assessment methodology (AM) and disclosure framework (DF) proposed by CPSS and IOSCO to assess compliance with the new global Principles for financial market infrastructures have two different purposes, being addressed to regulators and to infrastructures respectively. However, the WFC wonders whether the different formats being proposed (questions in the case of the AM, headings with narrative descriptions in the DF) will not create additional complexity and duplication1 when complying with the FMI Principles. In particular we fear that the narrative format being proposed in the new DF will not enhance transparency when compared with the former disclosure framework as it relies entirely on “free text” responses which will make consistency, and therefore comparisons between infrastructures, quite difficult.
In fact, we believe that a more efficient and transparent solution for FMI disclosures can be achieved by using the AM as a basis for FMI self-assessments, and then possibly removing some AM questions if the related responses include confidential information which should not be made publicly available.

Read the full WFC response

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