From:
Ex Parte Communication
Organization(s):
Philip Pettinato, Chief operating Officer
Patrick Trozzo, Chief Compliance Officer
Michael Haywood (LTD Group)
Comment Text:
Meeting with Reval
Friday, January 28, 2011
Memo from
Burns, Jeffrey P.
CFTC Staff :
Jeffrey Burns
Adedayo "Bill" Banwo
External Attendees :
Philip Pettinato, Chief operating Officer
Patrick Trozzo, Chief Compliance Officer
Michael Haywood (LTD Group)
Additional Information :
CFTC staff participated in a meeting with Reval discussing issues and questions related to the swap data repository (SDR) rulemaking. The meeting covered two broad topics: (1) SDR registration; and (2) data aggregation and reporting, with an emphasis on the expected goals of SDRs such as data collection, transparency and systemic risk.
SDR Registration
Reval believed that there should be separate repositories for collateral and collateral documentation, which are linked with transaction data. Letters of credit or commitment letters should factor into determining whether a SDR has adequate financial resources to operate, especially for small to medium SDR entities.
Data Aggregation and Reporting
Reval believes a "standardized grid" report format or "layers of aggregation" should be required to aid the Commission in aggregating market data for enforcement and systemic risk purposes.
Counterparty Risk
Reval believes that the most important regulatory function of the SDR should be measuring counterparty risk, and therefore, suggested additional reporting fields, particularly, regarding valuation and collateral.
