RFP: Commodity Derivatives Trade Repository Questions ... - ISDA

International Swaps and Derivatives Association, Inc.RFP: Commodity Derivatives Trade RepositoryQuestions Received - 4.06.2011Ques.NoDateRaisedRFPSectionCategory Question Response1 25-Mar 2.1 ScopeDo you know why the initial focuswill be on oil?This is consistent with the Commodity Steering Committee discussionswith the supervisors on logical phasing.2 29-Mar n/a n/aIf we declare our intention toreply on Friday 1st April, is itpublic information? And samequestion if we submit an answeron the 25th of April?For all of the submissions (including an intent to participate and RFPsubmission), the responses will be distributed to a sub-set of theCommodities Steering Committee for initial review and potentially to thewhole Commodities Steering Committee further along in the selectionprocess. The members of these groups are asked to keep the informationprivate and only distribute internally to those who are involved in theselection process. Any questions submitted in writing will be answered inwriting and published anonymously on the ISDA website for all potentialRFP respondents to review.3 29-Mar 2.2 FunctionI see from the RFP document thatyou refer to another document“Outline of Trade RepositoryFunctionality Being Sought byMembers of the OTC DerivativesRegulators' Forum” however Idon’t seem to be able to find thisdocument. Would it be possiblefor you to provide a copy?The 'ODRF' Trade Repository Guidelines are available here:http://www.otcdrf.org/documents/traderepositoryfunctionalityoutline.pdf

International Swaps and Derivatives Association, Inc.4 29-Mar n/a n/a5 30-Mar n/a n/a6 30-Mar 2.2 FunctionThe main question I had is relatedto the place of implementation ofthe target solution. I see theaddress on the document is theone of your London office, but youare based in New York. We weretherefore wondering if youplanned on installing andmanaging the system in the US orthe UK.Please can you let me know whichother organisations we arecompeting with in this RFPprocess?After reading the RFP responsedetails, my take is that ISDA islooking for a Service Provider toact as both the platform and theoperator of the repository. Wouldyou say that is accurate?In relation to the RFP process, ISDA will support in both London and NewYork. The location of the Trade Repository is yet to be determined and willbe discussed further during the RFP review process.The RFP was distributed widely and posted on the ISDA website and assuch we expect bids from a wide variety of Service Providers. We will notbe making publicly available the list of Service Providers that haveregistered their interest in participating.Correct.7 30-Mar 2.1 ScopeWhat is ISDA’s role in the traderepository, and is there arelationship with the CFTC ortrade repositories for other assetclasses (IRD, Credit)?ISDA, as an association, is acting on behalf of our membership and the OTCderivatives industry. We have relationships with global supervisors, andthe RFP was reviewed by a variety of the supervisory community prior topublication. ISDA will facilitate the process of selecting the serviceprovider and defining the terms of service, the principal contractual andfinancial relationships will be between the service provider and theparticipants. ISDA will not be a party to such principal contractual andfinancial relationship.ISDA has issued RFPs for Equity and Interest Rate Derivative Repositories,as indicated on our website.

International Swaps and Derivatives Association, Inc.8 30-Mar 2.1 Scope9 30-Mar 2.1 Scope10 31-Mar 2.2 Function11 31-Mar 2.2 Function12 31-Mar n/a n/aIn terms of the trades beingcaptured in the commodityrepository, do you have an idea ofwhat types of trades the RFP isalluding to as “exotics”?Do you expect power transactionsto be a large portion of the tradevolumes?What is ISDA's view on thephysical architecture of the TradeReporting Repository?Is a cloud solution, vendor-hostedsolution, or an on-premisessolution envisaged?Is any information available aboutprojected data volumes?Exotic trades are bespoke, non-standardized transactions done betweenthe parties. These are in-scope as per section 2.1.1 of the RFP.As per the RFP, the initial development phase will focus on OTC financialoil transactions.To be discussed as part of the RFP process.To be discussed as part of the RFP process. See section 2.2 of the RFP.As per the RFP, the initial development phase will focus on OTC financialoil transactions. We do not have any projected volume data at this time.13 31-Mar 2.1.2 Participants14 31-Mar 2.2 FunctionHow many participants areinitially/ultimately envisaged to beconnected to the Repository?Would participants be requiredthemselves to perform thenecessary standardization to asingle or limited set of availabledata submission methods, orwould you expect the Repositoryto deal with each Participant'sdata format specificities?All counterparties are encouraged to submit their relevant transactions tothe Repository. This will be discussed further as part of the RFP process.We expect the initial number of firms to be a mix of the G14 Dealerinstitutions and other Commodities Steering Committee (COSC)participants.As per Section 2.2 of the RFP, the Repository should have the ability tostandardize reference data. Additionally, reference data should leveragealready existing data available in other OTC Derivative Trade Repositoriesand placeholders for UCI, UPI and USIs should be incorporated.

International Swaps and Derivatives Association, Inc.15 31-Mar 2.2 Function16 31-Mar 2.2 Function17 31-Mar 5.2 FpML18 31-Mar 5.2 FpML19 31-Mar 5.2 FpMLHow many end users would therebe on the system? How manyreport requests would theygenerate?What is the expected frequency ofdata delivery? Is it initially dailywith an option to submit datamore frequently (since RFPmentions readiness for intra-dayreporting)? Or is a constant 'dripfeed' approach to loading dataduring the day required?RFP states "Examples of currentOTC commodity FpML schemascan be provided upon request."We would like to receive suchexamples.Of the entire FpML standard,which or how many FpMLschemas will actually be neededfor this Repository?Which version (s) of the FpMLstandard will need to besupported?To be discussed as part of the RFP process. Please keep in mind that therepository will need to generate reports for relevant regulators, as well asmarket participants.As per section 2.2. of the RFP, reporting produced from the repositoryshould be flexible and timely, allowing for ad hoc data requests. Theability to move from daily to intra-day reporting should be available.The most recently released FpML version 5.1 schema (and more e.g.,online documentation) are available at http://www.fpml.org/spec (youwill need to setup a free account and acknowledge the FpML license.)The Commodity specific FpML schemas.The most recent version is 5.1 and is available via the link above.20 31-Mar 5.5 SecurityCan you qualify further what isunderstood with "Chinese Walltype controls" in the Securitysection?In this context, the RFP is looking for Service Providers to describe howthey would ensure that the Repository data is segregated and keptconfidential only to specific, approved users within a firm.

International Swaps and Derivatives Association, Inc.27 31-Mar n/a n/a28 31-Mar n/a n/a29 31-Mar 2.2 Function30 31-Mar 2.2 Function31 31-Mar 2 OverviewBy conducting this RFP Process,will you be in a position toinfluence the CFTC in writing itsfinal rules?By conducting this process, isthere an implication that theselected vendor would have anydifferent standing with CFTC thanany other applicant forregistration as an SDR?Would the selected serviceprovider be the owner of the TRR,or serve as a Vendor to some thirdparty investor who is backing theprocess?Would you faciliate the industryeffort to define UPI codes andswap dataset content forcommodity asset subclasses,starting with financial oil,particularly if multiple SDRs arestill permitted in the final rules?Is it your view that there shouldonly be one SDR per asset class orcommodity asset subclass?No.No. Individual Swap Data Repository qualifications are contained in TheDodd-Frank Wall Street Reform and Consumer Protection Act and its rules.To be determined by the RFP process. This will depend on each individualService Provider.Yes. ISDA has a group currently looking at facilitating these discussions.The intention of this RFP is not to pre-suppose any market infrastructureas this will evolve as part of the application, selection and developmentprocess.