Working Group 6 – Report Transparency

Working Group # 6 Principle # 23 Disclosure of rules, key procedures, and market data 1.What constitutes "compliance" with the Principle? Describe (in specific terms) the state characteristics of a CSD that fully meets the requirements of the Principle. FMI has written rules and procedures of ALL the services and processes. Including participant responsibilities, risk (including cross-border linkages), fees and costs and discounts with the appropriate explanation; exception: processing. In market data include general statistics (number of transactions, settlement value, etc.) corporate action information. Make it available via the website (offer links to cross-border linkages rules), publications, notices to participants. Include this in the contracts to participants with emphasis on referencing rules and procedures of the FMI and any other rules, and jurisdictions related to linkages with other FMIs. Have a training program for new participants and periodic training for existing participants.

2. In relation to the Key Considerations for the Principle, what metrics/data should a CSD compile in order to demonstrate compliance? How might this data be sourced? Have a compilation of all the relevant documents in a single publication. Have a process for any updates to the rules and procedures. Have a matrix that relates the service and process with the relevant regulation Have an education and training program Working Group # 6 Principle / Principio # 23 Disclosure of rules, key procedures, and market data

3. What “result levels" with respect to these metrics/data should a CSD achieve in obtaining "compliance"? Why? Obtain statistics from customer support regarding the types of questions from participants Require participants to educate their customers regarding rules, processes and services. Include programs to educate investors. Working Group # 6 Principle # 23 Disclosure of rules, key procedures, and market data

4. What, if any, provisions should you (as an FMI) be making to ensure continued adherence to the principle(s), for example in times of market or operational distress? Have a process for any updates to the rules, procedures, services and fees. Review what the FMI is publishing. Publish result of stress testing, BCP etc.. Have step by step summary of procedure to follow on a crisis. Make sure the proper persons at the Participants are familiar with these prior to any crisis. Publish the results of the CPSS-IOSCO Disclosure Framework keeping in mind any confidential or sensitive information. Working Group # 6 Principle # 23 Disclosure of rules, key procedures, and market data

Working Group # 6 Principle # 24 Disclosure of market data by trade repositories 1.What constitutes "compliance" with the Principle? Describe (in specific terms) the state characteristics of a CSD that fully meets the requirements of the Principle. To have a complete reliable data base without duplicated or fragmentized information Ensure you are providing the regulator timely data, with relevant breakdown for the authorities to monitor participants’ activities. Ensure that the public has just the necessary information relevant to them and not disclose any confidential information. Have interoperability with different sources /feeds of the data, flexibility to receive wide variety of formats. Include clearable and non-clearable transactions. Standard contracts and exotic contracts.

2. In relation to the Key Considerations for the Principle, what metrics/data should a CSD compile in order to demonstrate compliance? How might this data be sourced? Offer aggregate data to the public on volumes, values, and open positions. Have reports on submission timing to the authorities Do periodic reconciliation and cross checks to make sure you have all the data and no duplicates Have system alerts for fragmentized and duplicated information Document information security rules and audits Working Group # 6 Principle # 24 Disclosure of market data by trade repositories

3. What “result levels" with respect to these metrics/data should a CSD achieve in obtaining "compliance"? Why? To have 100% accuracy on the previously mentioned reports. Meeting deadlines from authorities and regulation Working Group # 6 Principle # 24 Disclosure of market data by trade repositories

4. What, if any, provisions should you (as an FMI) be making to ensure continued adherence to the principle(s), for example, in times of market or operational distress? Have a clear process for submitting information Make sure that trade data is updated Make sure operational risk is managed (BCP, Data recovery, back-up facilities, etc.) Working Group # 6 Principle # 24 Disclosure of market data by trade repositories