ISDA appreciates the IOSCO Task Force on Cross-Border Regulation’s engagement with the industry at meetings in Hong Kong on April 7, London on April 25 and Washington, DC on April 28, 2014. Further to discussions during those meetings, ISDA wishes to comment on a number of specific issues, and highlight how OTC derivatives markets have been affected by a lack of effective cross-border regulatory harmonization. OTC derivatives markets have historically been the most global in nature of all financial markets, and the absence of consistency in regulatory reform is having a direct impact on these markets as a result. This also affects other product areas and, more importantly, threatens the efficiency with which ‘real economy’ end-users can manage and transfer business risk to financial markets.
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