Comment Text:
GS1, GS1 US, and Financial InterGroup are pleased to submit this response to the CFTC's request for comments regarding Swap Data Recordkeeping and Reporting Requirements.
Our response is in the attached file, 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
