Stuff happens. Floods in Louisiana this summer. Fires in California and the northwest. Brownouts. Blackouts. Acts of…bad people?
Do you have a backup plan?
Earlier this month Timothy Massad, Chairman of the U.S, Commodities and Futures Trading Commission (CFTC) discussed new documents released by the Committee on Payments and Market Infrastructures (CPMI), the International Organization of Securities Commissions (IOSCO), and the Financial Stability Board (FSB) reviewing issues related to clearinghouse resiliency, recovery, and resolution planning.
Securing financial markets is critical and the CFTC is making it a high priority. Chairman Massad says, that “In addition to helping lead or participating in these international workstreams, we have been very busy on these issues at home. For example, our examination and risk surveillance programs focus on clearinghouse resiliency on an ongoing basis. We are working with our major clearinghouses to review their recovery plans and rule changes and are engaged in discussions with them and other market participants on how significant problems would be handled.”
Are you ready?
While most of the regulatory bodies seek oversight and assurance of central counterparties (CCPs) on certain principles and key considerations, including risk management, they also will be paying special attention to governance and oversight.
Strong governance is critical, as is a fully-communicated back-up plan, and written supervisory procedures — a document trail if you will. Regulators will increasingly require that CCPs have documented governance arrangements that provide clear and direct lines of responsibility and accountability and clearly specified roles and responsibilities for the CCP’s board of directors (or equivalent) and the CCP’s management. Moreover, each CCP and the authorities responsible for its regulation, supervision, and oversight should ensure all “t’s” are crossed and all “i’s” are dotted.
Whether you are a broker-dealer, FSA, RIA, or any other entity playing in the financial services arena, be aware that what is required of CCPs likely already is or going to be required of you.
Will you be ready…then?
The answer to that question depends on your platform. What are you using?
If you are charged with compliance, you know you’re facing increased oversight which requires you to juggle more paper, more files, more data. Where do you keep it? Regulatory compliance requirements are getting more all-consuming and complying can often times feel like an undertaking without end. How do you ensure that every member of your team is aware of the rules and compliant? If your compliance function is under pressure to do more with less, what are the options?
Let’s talk (212-233-1155). Ask about Patrina’s comprehensive compliance solutions, compliant recordkeeping , and even data capture/storage/retrieval specifically designed for the financial services community. Be safe, secure, compliant.