一些人认为, had data on over-the-counter (OTC) derivatives transactions been available before the financial crisis in 2008, 风险的积累本可以得到完全不同的预见和管理. This is what led to G20 demands that all derivatives products be reported to trade repositories and made available to 监管机构. 但早在2010年, 在第一个存储库上线之前, 监管机构, 存 and others in the industry had identified derivatives data fragmentation issues and began raising awareness of the need to implement standards globally at that time. 因此，衍生品市场是相互联系的，也是全球性的, 衍生品数据需要在所有司法管辖区保持一致和可读.
快进11年，可以说, 毫无疑问, that a great amount of progress has been made on global data standardization for the purposes of monitoring OTC derivatives systemic risk and identifying market abuse. 例如, 唯一vnsr威尼斯城官网登入标识符(UPI), which is currently under development by the 国际 Organization of Securities Commissions (IOSCO) in partnership with the Bank for 国际 结算s’ (BIS) Committee on Payments and Market Infrastructures (CPMI), 是否会在2022年的某个时候用于全球范围的报道. The Unique Transaction Identifier (UTI) is also mandated for use in trade reporting globally, 除了法人实体标识符(LEI). 此外, 努力确保数据的协调和标准化, FSB同意加强对lei的监管, 监管监督委员会(ROC)下的upi和uti.
最近, 监管机构 and standards setting bodies have shifted their attention to the development and agreement of Critical Data Elements (CDE), 哪一个也将由中华民国管辖. The CDE consists of 110 proposed data elements that the CPMI-IOSCO proposed to be used by firms when reporting OTC derivatives transactions. CPMI-IOSCO还建议治理功能涵盖维护, oversight and implementation of CDEs and provided technical guidance around the implementation of the CDE by authorities. CPMI-IOSCO suggested that CDE should be defined and maintained in the ISO 20022 data dictionary stating that it will facilitate their inclusion into standardized messages and help participants program CDE into electronic messaging systems, 从而鼓励广泛实施CDE并提高数据质量.
“快进11年，可以说, 毫无疑问, that a great amount of progress has been made on global data standardization for the purposes of monitoring OTC derivatives systemic risk and identifying market abuse."
虽然ISO 20022的工作正在进行中，但它远未最终确定. Important to note is that the ISO 20022 Derivatives SubSEG working group is actively working on establishing the message definition. It is imperative that the group build from the industry’s years of experience reporting in structured XML standards. 例如, the proposed ISO 20022 CDE schema is modeled after a message created in 2018 that was not designed for reporting CDE data attributes. 除了, 有了这个特殊的图式, 技术定义并不总是与CDE CPMI-IOSCO技术指南一致, 哪些会导致不同制度间的采用不一致. The industry must ensure that the first ISO 20022 CDE schema uniformly defines the CDE attributes and simultaneously allows 监管机构 to enhance and version the message while not combining non-CDE data attributes with CDE attributes.
看看cde的采用情况, 监管机构 around the world have subsequently expressed their commitment to rewrite their rules based on the adoption of CDE. 例如, the Commodity Futures Trading Commission (CFTC) has finalized its rules incorporating CDE and the date for implementation will be in May 2022. The European Securities and Markets Authority (ESMA) has recently published its technical standards, 包括CDE, 根据EMIR改装规定，该规定正在得到立法者的批准. 其他监管机构现在也在做同样的事情.
然而, in adopting CDEs we are seeing that differences across jurisdictions are emerging once again. 基于存进行的分析, 在观察CFTC和ESMA之间的共同点时, both the CFTC rules revisions and ESMA’s EMIR Refit adopt a majority of the CDEs as per CPMI-IOSCO guidance without any deviation or with only a difference in naming. 具体来说，CFTC采用了71%的CDE, ESMA采用了75%的CDE，没有偏差. 但重要的是，在它们对齐的cde中，只有51个匹配并在它们之间共享. An additional 26 CDEs partially match and are adopted by both but are not aligned in format, 价值和定义. 10 CDEs are not adopted by either regulator and 23 CDEs are adopted by only one regulator. 这就引出了一个问题，即是否所有110个cde都是必要的.
此外, each jurisdiction is able to ask for additional data elements as an extension to the standards, if they believe that the 110 data elements in the proposed guidelines are insufficient for their needs or mandate.
While 存 is supportive of the need for additional data elements for each regulator’s jurisdiction, 该行业必须坚持使用关键核心数据集，以避免额外的成本, 复杂性和碎片化, 同时也使监管机构能够识别系统风险. 另外, 哪些地方的CDE属性没有被监管机构统一采用, it is possible that this non-uniform adoption will introduce additional complexity to the CDE elements within the ISO 20022 schema. This increases the operational burden on trade repositories to manage validations for CDE attributes separately for each jurisdiction.
像这样, it is essential that policymakers identify a universal short list of CDEs for trade reporting across multiple jurisdictions that can be used to identify risk as well as other CDE that are commonly desired. The LEI ROC should oversee a review of which CDEs can be removed to create a short list of CDEs that can be universally and uniformly implemented. 进一步, CDEs should universally and uniformly be adopted by all 监管机构 with additional jurisdictional non-CDE fields if a particular regulator determines additional data is necessary to meet their local mandate. 最后, 一个特定的监管机构是否应该不能统一采用所有的cde, 所采用的cde应在格式方面得到一致的执行, 价值和定义.
If the G20 goal of creating transparency in the global OTC derivatives market in order to mitigate systemic risk is to be reached, it is important that policymakers consider implementing recommended reforms that enable the aggregation and analysis of data reported to trade repositories across multiple jurisdictions. 然而, if jurisdictions continue to apply derivatives reporting rules according to different standards, 合规成本只会增加，聚合数据的能力也会增加, 因此，监控和减轻系统性风险将受到严重损害.
本文最初发表于 汤森路透监管 情报，2021年4月22日.