April 12, SLIDE 1 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FpML Representation for Public Price Transparency Reporting FX Products ® ISDA is a registered trademark of the International Swaps & Derivatives Association, Inc. ® FpML is a registered trademark of the International Swaps & Derivatives Association, Inc. ISDA Presented to FpML FX WG April 2012

April 12, SLIDE 2 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG Agenda FpML Regulatory Reporting Working Group Views in FpML High-level overview of transparency changes for FX Details of transparency changes

April 12, SLIDE 3 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FpML Regulatory Reporting Working Group (RPTWG)

April 12, SLIDE 4 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG RPTWG Objectives Define FpML Messages to support regulatory reporting requirements –Sending public and non-public information to SDRs –As desired, publishing info from SDRs Initial focus on US (Dodd-Frank), but messages should be designed to work for all regulators worldwide

April 12, SLIDE 5 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG RPTWG Status Has defined reporting processes and cross- product surveillance fields Defined 2 views for reporting to SDRs –Transparency: Real time public reporting (Part 43) –Recordkeeping: Primary Economic Terms, etc. (Part 45) Refining views for use by SDR offerings Working on related activities –E.g., Product type taxonomy coding scheme, USI representation

April 12, SLIDE 6 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG Views in FpML -Views are intended to provide multiple product representations, from very loose to very tight. -Confirmation view contains many details, precise description -Reporting Views require addition of some elements (extensions), ability to leave out many.

April 12, SLIDE 7 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG Comparing Views MODFOLLOWING GBLO USNY … Real-time reporting (date only) Record-keeping (date + adjustments)

April 12, SLIDE 8 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG Transparency View Public real-time reporting is supported in the transparency view –publicExecutionReport message Includes stripped down product representation (no proprietary info, omit details that dont strongly affect price) Covers standard OTC products, plus generic product for less common products RPTWG developed initial models based on input from a few dealers FX product working group should validate and refine the model

April 12, SLIDE 9 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FX Forward

April 12, SLIDE 10 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FX Forward Non-deliverable settlement: The proposal is to remove the specification of such clause as part of the real-time price reporting, the rational being that it is understood as being bespoke.

April 12, SLIDE 11 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FX Swap

April 12, SLIDE 12 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FX Swap Non-deliverable settlement: Similar to the FX Forward, the proposal is to remove the specification of such clause as part of the real-time price reporting, the rational being that it is understood as being bespoke. The schema adjustment would apply to both legs of the swap (nearLeg as well as farLeg).

April 12, SLIDE 13 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FX Options

April 12, SLIDE 14 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FX Options Settlement terms: With the payment date specified as part of the paymentDate construct, the proposal is to remove the settlementInformation block, as those further settlement terms are not required for price transparency reporting.

April 12, SLIDE 15 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FX Options Non-deliverable settlement: Similar to the FX Options, the proposal is to remove the specification of such clause as part of the real-time price reporting, the rational being that it is understood as being bespoke.

April 12, SLIDE 16 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG Details of Transparency Changes RPTWG has developed a detailed report listing –Elements that have been omitted in Transparency view –Elements that are required in Transparency view (See detailed report)

April 12, SLIDE 17 Copyright © 2011 International Swaps and Derivatives Association, Inc. FpML Reporting WG FX WG needs to validate the transparency view model Finalized changes should be incorporated by the TR Conclusion