Comment Text:
GS1, GS1 US, and Financial InterGroup are pleased to submit a comprehensive response to the CFTC's request for comments regarding Swap Data Recordkeeping and Reporting Requirements. Due to technical limitations, we have submitted our proposal at regulations.gov under Docket CFTC-2010-0179-0001.
Our response is in a file attached to our response at regulations.gov, and consists of three parts: a 6-page transmittal letter that summarizes our response, a detailed analysis and proposal, and supporting appendices.
The following is the table of contents for the detailed analysis and proposal.
- A proposal to the Commodity Futures Trading Commission
- Introduction
- Importance of Reference Data
- Inadequate Regulatory Structures and Vulnerabilities
- Problem of Systemic Risk
- Cost of the Current Global Reference Data System
- Figure 1 - Governments' Potential Legal Entity Registration and Distribution Approach
- Outline of the Proposed Solution
- Universal Identification for the Financial Industry
- Legal Entity Identifier - the Global Business Entity Identifier (GBEI)
- Financial Instrument Identifier - the Global Financial Instrument Identifier (GFII)
- Financial Event Identifier - the Global Financial Event Identifier (GFEI)
- Issuance of GBEIs and Other Identifiers
- Figure 2 - Global Business Entity Identifier Issuance Process
- Capacity
- Figure 3 - Variable Length GS1 Company Prefix Within a Fixed Length Key
- Non-Significance of the Company Prefix
- Figure 4 - Common Occurring Corporate Events in the Life Cycle of a Legal Entity
- Registation of Identifiers and Reference Data
- Organizational Structure of Registration Authorities
- Definition, Verification, and Access of Reference Data
- Financial Reference Data and the Internet
- Implementation Timeline
- Summary of CFTC Requirements
- Requirements Regarding LEI Characteristics
- Requirements Regarding Institutional Arrangements for Issuing LEIs
- Requirements Regarding Institutional Arrangements for Developing, Maintaining, and Publishing LEI Reference Data
