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To deliver anticipated benefits of post-trade transparency and to minimize potential costs, IOSCO jurisdictions may wish to consider the following:

  • Limiting the delay between time of execution and time of public dissemination of the price and volume of an individual CDS transaction;
  • Whether special rules should govern the timing and scope of public dissemination of the price and volume of large or “block” transactions and/or transactions in an illiquid market and, if so, rules that determine what constitutes such a transaction;
  • Measures to ensure confidentiality of the identities of the market participants, which could include “capping” or “bucketing” the true notional size of the transaction, particularly in small or illiquid markets in which trading is concentrated in one or two key market participants;
  • Whether the potential for loss of confidentiality in small or illiquid markets may be less pronounced for CDS products that are frequently traded in other larger, more liquid markets;
  • Utilizing relevant data to study the impact of post-trade transparency;
  • Structuring the system of post-trade transparency (whether as a public utility or a private venture) to promote compliance across all market participants subject to mandatory post-trade transparency, equitably allocate its costs and reap fully its benefits;
  • Maintaining sufficient flexibility to adapt to changing market conditions;
  • Implementing post-trade transparency in phases, focusing on the most frequently traded standardized products and/or the largest, most frequent or best prepared market participants in earlier phases and on less frequently traded and non-standardized products and/or smaller, less frequent or less prepared market participants in later phases; and
  • Consulting with authorities in other jurisdictions as appropriate, recognizing that each member jurisdiction is best placed to judge the extent of any such consultation, local market characteristics and the appropriate time and manner for enhancing post-trade transparency for CDS that trade in its respective market.