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The purpose of ''''macroprudential  financial policy'''' is to preserve the integrity of the financial system in view of the threat to its existence posed by the [[crash of 2008]]. This article summarises the measures taken, agreed and under discussion as at  November 2009.
  (The former text of this renamed article has been temporarily transferred to my sandbox to facilitate restructuring<br>[[User:Nick Gardner|Nick Gardner]] 16:22, 15 January 2010 (UTC))


:''(for definitions of the terms shown in italics, see the glossary on the [[/Related Articles|related articles subpage]])''<br>
:''(links to the regulatory institutions and legislation that are referred to are available on the [[/Addendum|addendum subpage]])''


==Background: pre-crash  financial regulation==
==Background: Regulatory Failure==
Governments have long been aware of the danger that a loss of confidence following the failure of one bank could lead to the failure of others, and to limit that danger they traditionally required all banks to maintain minimum ''reserve ratios''. Following the [[crash of 1929]]  they also imposed restrictions upon the activities of the ''commercial banks''. In the United States, for example, the [[Glass-Steagall Act]] of 1934 prohibited their participation in the activities of ''investment banks''<ref>The Glass-Steagall Act was largely repealed by the [[Gramm-Leach-Bliley Act]] of 1999</ref>. In the 1980s, however, there was a general move toward "deregulation",  those restrictions were dropped and  reserve requirements were relaxed. There followed a period of financial innovation and  substantial change in the nature of banking<ref>[http://www.bis.org/publ/econ43.pdf?noframes=1 Claudio Borio and Renato Filosa: ''The Changing Borders of Banking'', BIS Economic Paper No 43, Bank for International Settlements December 1994]</ref>.  The perception of a resulting increase in danger of  systemic failure led, in 1988, to the  publication of a set of regulatory recommendations that related a bank's required reserve ratio to the riskiness of its loans <ref>[http://www.bis.org/publ/bcbsc111.pdf?noframes=1, ''The Basel Capital Accord'' (Basel I) Basel Committee for Banking Supervision 1988]</ref> and, in 2004,  to revised recommendations <ref>[http://www.bis.org/publ/bcbsca.htm Revised International Capital Framework, (Basel II) Basel Committee on Banking Supervision 2006]</ref>  requiring banks to take more detailed account of the riskiness of their loans. Those recommendations were widely adopted, but their inadequacy was revealed by  the ''[[crash of 2008]]'' when the global banking system suffered its "most severe instability since the outbreak of World War I" <ref>[http://www.bankofengland.co.uk/publications/inflationreport/infrep.htm ''Overview of the November Inflation Report'', Bank of England 2008]</ref>. and threatened the collapse of its entire financial system. That narrowly-averted catastrophe prompted the urgent consideration of measures to remedy the deficiencies of the regulatory system. Recognition of the international character of the problem led to the inauguration of a series of [[G20 summit]]s, initially  to formulate  measures  to combat the [[recession of 2008]] and subsequently to consider  measures  to reduce the danger of a future collapse of the international financial system.
:''(For accounts of the historical development of financial regulation, see paragraph 4 of the article on [[banking]] and paragraph 5 of the article on [[financial economics]])''


==Post-crash proposals==
==Microprudential policy==
===Micro- and macroprudential regulation===
===Pre-crash policy===
A paper by the United States Department of the Treasury makes the point that "a narrow micro-prudential concern for the solvency of individual firms, while necessary, is by itself insufficient to guard against financial instability. In fact, actions taken to preserve one or a few individual banking firms may destabilize the rest of the financial system"<ref  name=treasury>[http://www.treas.gov/press/releases/docs/capital-statement_090309.pdf ''Principles for Reforming the U.S. and International Regulatory Capital Framework for Banking Firms'', US Treasury Department, September 2009]"</ref>.  A Bank of England of England discussion paper goes further,  explaining  that  microprudential policymakers might impose severe lending restrictions to guard against individual bank failures,  whereas  macroprudential policies would take account of the long-term damage to the banking system and to  the economy that  could result from the consequent credit shortages<ref>[http://www.bankofengland.co.uk/publications/other/financialstability/roleofmacroprudentialpolicy091121.pdf ''The Role of Macroprudential Policy'', a discussion paper, Bank of England, November 2009]</ref>


===Problems and remedies===
===Post-crash proposals===
====Leverage====
====Leverage====
The Turner Review recommended raising banks' ''reserve ratio'' requirements to levels substantially above those required under ''Basel 2'' and introducing a  discretionary counter-cyclical element that would raise the required ratio during economic booms <ref name=turner>[http://www.fsa.gov.uk/pubs/other/turner_review.pdf ''The Turner Review: A regulatory response to the global banking crisis'', Financial Services Authority, March 2009]</ref>. The Warwick Commission on international financial reform was also in favour of counter-cyclical regulation but suggested that it should be rules-based to help central banks to resist political opposition to "taking away the punchbowl when the part gets going". Its purpose would be to persuade banks to put away money during a boom-at a time when they would be motivated to run down their reserves<ref name=warwick>[http://www2.warwick.ac.uk/research/warwickcommission/report/swc_report.pdf ''The Warwick Commission on International Financial Reform: In Praise of Unlevel Playing Fields'', (The report of the second Warwick Commission) University of Warwick, November 2009]</ref>.  
The Turner Review recommended raising banks' ''reserve ratio'' requirements to levels substantially above those required under ''Basel 2'' and introducing a  discretionary counter-cyclical element that would raise the required ratio during economic booms <ref name=turner>[http://www.fsa.gov.uk/pubs/other/turner_review.pdf ''The Turner Review: A regulatory response to the global banking crisis'', Financial Services Authority, March 2009]</ref>. The Warwick Commission on international financial reform was also in favour of counter-cyclical regulation but suggested that it should be rules-based to help central banks to resist political opposition to "taking away the punchbowl when the part gets going". Its purpose would be to persuade banks to put away money during a boom-at a time when they would be motivated to run down their reserves<ref name=warwick>[http://www2.warwick.ac.uk/research/warwickcommission/report/swc_report.pdf ''The Warwick Commission on International Financial Reform: In Praise of Unlevel Playing Fields'', (The report of the second Warwick Commission) University of Warwick, November 2009]</ref>.  
====Risk management====
====Risk management====
The de Larosière Group of European regulators proposed that the board members of banks should be required to abandon the practice of relying upon risk models that they do not understand, and to make fuller use of their professional judgment.
The de Larosière Group of European regulators proposed that the board members of banks should be required to abandon the practice of relying upon risk models that they do not understand, and to make fuller use of their professional judgment.
<ref name=deL>[http://ec.europa.eu/internal_market/finances/docs/de_larosiere_report_en.pdf ''The de Larosière Report (Report of the High-Level Group on Financial Supervision in the EU'', European Commission, February 2009]</ref>.
<ref name=deL>[http://ec.europa.eu/internal_market/finances/docs/de_larosiere_report_en.pdf ''The de Larosière Report (Report of the High-Level Group on Financial Supervision in the EU'', European Commission, February 2009]</ref>.


New risk management standards  were issued by the Basel Committee on Banking Supervision in  September 2008<ref>[http://www.bis.org/publ/bcbs144.pdf ''Principles for Sound Liquidity Risk Management and Supervision'', Basel Committee on Banking Supervision, September 2008]</ref>
New risk management standards  were issued by the Basel Committee on Banking Supervision in  September 2008<ref>[http://www.bis.org/publ/bcbs144.pdf ''Principles for Sound Liquidity Risk Management and Supervision'', Basel Committee on Banking Supervision, September 2008]</ref>.
 
====Derivatives====
====Derivatives====
The rôle of financial derivatives in the crash of 2008 is a topic of controversy among economists. Professor  Hyun Song Shin has argued that their use had undermined the stability of the financial system by  concentrated risks in the banking system <ref>[http://www.voxeu.eu/index.php?q=node/3287 C ''Securitisation and Financial Stability'', Vox 18 March 2009]</ref>, and the eminent economist Joseph  Stiglitz has sugqested that major banks should not be allowed to hold derivatives, especially credit default swaps<ref>[http://www.bloomberg.com/apps/news?pid=20601103&sid=a65VXsI.90hs Ben Moshinsky:  ''Stiglitz Says Banks Should Be Banned From CDS Trading '', Bloomberg October 12 2009]</ref>, but Professor Myron Scholes has described  proposals to ban them as "a luddite response".  The regulatory authorities do not appear to be considering a ban on their use, but they are formulating measures to improve their ability to monitor them. The United States Department of the Treasury has proposed legislation to require clearing of all standardized over-the-counter derivatives through regulated central counterparties who must impose robust margin requirements and risk controls   
The rôle of financial derivatives in the crash of 2008 is a topic of controversy among economists. Professor  Hyun Song Shin has argued that their use had undermined the stability of the financial system by  concentrated risks in the banking system <ref>[http://www.voxeu.eu/index.php?q=node/3287 C ''Securitisation and Financial Stability'', Vox 18 March 2009]</ref>, and the eminent economist Joseph  Stiglitz has sugqested that major banks should not be allowed to hold derivatives, especially credit default swaps<ref>[http://www.bloomberg.com/apps/news?pid=20601103&sid=a65VXsI.90hs Ben Moshinsky:  ''Stiglitz Says Banks Should Be Banned From CDS Trading '', Bloomberg October 12 2009]</ref>, but Professor Myron Scholes has described  proposals to ban them as "a luddite response".  The regulatory authorities do not appear to be considering a ban on their use, but they are formulating measures to improve their ability to monitor them. The United States Department of the Treasury has proposed legislation to require clearing of all standardized over-the-counter derivatives through regulated central counterparties who must impose robust margin requirements and risk controls   
<ref>[http://www.ustreas.gov/press/releases/tg129.htm ''Regulatory Reform Over-The-Counter (OTC) Derivatives'', US Department of the Treasury, May 13 2009]</ref>, and similar measures are considered in a European Commission consultation paper on possible derivatives legislation<ref>[http://ec.europa.eu/internal_market/consultations/docs/2009/derivatives/derivatives_consultation.pdf ''Possible initiatives to enhance the resilience of OTC Derivatives Markets'', (Consultation Document), European Commission, 3 July 2009]</ref> that may be expected to be discussed in forthcoming meetings of an international regulators forum<ref>[http://www.banque-france.fr/gb/supervi/telechar/OTCD_Regulators_Forum_Press_Release.pdf ''A Global Framework for Regulatory Cooperation on OTC Derivative CCPs and Trade Repositories'', Banque de France, September 24, 2009]</ref>
<ref>[http://www.ustreas.gov/press/releases/tg129.htm ''Regulatory Reform Over-The-Counter (OTC) Derivatives'', US Department of the Treasury, May 13 2009]</ref>, and similar measures are considered in a European Commission consultation paper on possible derivatives legislation<ref>[http://ec.europa.eu/internal_market/consultations/docs/2009/derivatives/derivatives_consultation.pdf ''Possible initiatives to enhance the resilience of OTC Derivatives Markets'', (Consultation Document), European Commission, 3 July 2009]</ref> that may be expected to be discussed in forthcoming meetings of an international regulators forum<ref>[http://www.banque-france.fr/gb/supervi/telechar/OTCD_Regulators_Forum_Press_Release.pdf ''A Global Framework for Regulatory Cooperation on OTC Derivative CCPs and Trade Repositories'', Banque de France, September 24, 2009]</ref>
====Off-balance-sheet vehicles====
====Off-balance-sheet vehicles====
The  international [[Financial Stability Board]] has issued new disclosure standards  for  ''off-balance sheet'' vehicles, and  has recommended the imposition of higher capital requirements where appropriate.
The  international [[Financial Stability Board]] has issued new disclosure standards  for  ''off-balance sheet'' vehicles, and  has recommended the imposition of higher capital requirements where appropriate.


====Asset-price bubbles====
Frederic Mishkin has noted that [[asset price bubbles]] that involve fluctuations in the supply of credit are far more damaging than those that do not <ref>[http://www.ft.com/cms/s/0/98e7c192-cd5f-11de-8162-00144feabdc0.html Frederic Mishkin: ''Not all Bubbles Present a Risk to the Economy'', Financial Times, 9th November 2009]</ref>. The "dot.com" bubble, for example did little damage because it was not credit-financed.  A Bank of England discussion paper has examined the regulatory regime of ''dynamic provisioning'' recommended by the de Larosière Group<ref name=deL/> - a rule-based scheme that requires banks to build up  provisions  against performing loans in an upturn, which can then be drawn down in a recession. It notes that the scheme did not appear to have smoothed the supply of credit, but may have made banks more resilient<ref>[http://www.bankofengland.co.uk/publications/other/financialstability/roleofmacroprudentialpolicy091121.pdf ''The Role of Macroprudential Policy'', a discussion paper, Bank of England, November 2009]</ref>. A suggestion by International Fund economists that [[monetary policy]] should be used to "lean against" asset price booms<ref>[https://www.imf.org/external/pubs/ft/weo/2000/01/pdf/chapter3.pdf''Asset Prices and the Business Cycle'', World Economic Outlook, Chapter 3, International Monetary Fund, May 2000]</ref><ref>[http://www.imf.org/external/pubs/ft/weo/2009/02/pdf/c3.pdf ''Lessons for Monetary Problems from Asset Price Fluctuations'',  (World Economic Outlook October 2009 Chapter 3) International Monetary Fund 2009]</ref> was not well received by central bank leaders<ref>[http://www.federalreserve.gov/BoardDocs/Speeches/2002/20021015/default.htm Ben Bernanke: ''Asset-Price "Bubbles" and Monetary Policy'' (Speech to the New York Chapter of the National Association for Business Economics, New York, New York, October 15 2002) Federal  Reserve Board 2002]</ref><ref>[http://www.ecb.int/press/key/date/2005/html/sp050608.en.html Jean-Claude Trichet: ''Asset price bubbles and monetary policy'',(Mas lecture, 8 June 2005) European Central Bank, 2005]</ref>, but the international Warwick Commission insisted that "inflation targeting ... needs to be supplemented by some form of regulation specifically aimed at calming asset markets when they become overheated" <ref>[http://www2.warwick.ac.uk/research/warwickcommission/report/swc_report.pdf ''The Warwick Commission on International Financial Reform: In Praise of Unlevel Playing Fields'', (The report of the second Warwick Commission) University of Warwick, November 2009]</ref>. The possibility of using [[fiscal policy]] is also under consideration. In response to a G20 request, the International Monetary Fund has agreed to investigate the feasibility of discouraging speculation by means of a global transactions tax
<ref>[http://www.cbi.org.uk/ndbs/press.nsf/0363c1f07c6ca12a8025671c00381cc7/403601cabba1738880257677005d24f0?OpenDocument Speech by Dominique Strauss-Kahn (the IMF's Managing Director), to the Confederation of Brtish Industry's annual conference November 23 2009]</ref>
====Too-big-to-fail====
The UK's Financial Standards Authority identified three aspects of the too-big-to-fall problem as:
*the ''moral hazard'' created if uninsured creditors of large banks believe that a systemically important bank will always be rescued, removing the incentive to impose discipline and  prompting them to reduce their interest rates;
*the  costs of  rescue operation and the unfairness of the "socialisation of losses"; and
*the possibility that rescue might cost more than the host country could afford<ref name=T2>[http://www.fsa.gov.uk/pubs/discussion/dp09_04.pdf ''Turner Review Conference Discussion Paper: A regulatory response to the global banking crisis: systemically important banks and assessing the cumulative impact'', Financial Services Authority, October 2009]</ref>.
The US Treasury, in a paper published in September 2009, suggested that "systemically important firms" should be
subject to higher capital requirements than other firms
<ref>[http://www.treas.gov/press/releases/docs/capital-statement_090309.pdf ''Principles for Reforming the U.S. and International Regulatory Capital Framework for Banking Firms'', US Treasury Department, September 2009]</ref>, and a G20 finance summit made the same suggestion<ref>[http://www.g20.org/Documents/FM__CBG_Declaration_-_Final.pdf ''Declaration on Further Steps to Strengthen the Financial System'', Meeting of Finance Ministers and Central Bank Governors, London, 4-5 September 2009]</ref>.
A survey-based analysis of the factors affecting organisation's systemic importance was published by a group of international organisations in October 2009 <ref>[http://www.financialstabilityboard.org/publications/r_091107d.pdf ''Guidance to Assess the Systemic Importance of Financial Institutions, Markets and Instruments: Initial Considerations — Background Paper'', Prepared by: Staff of the International Monetary Fund and the Bank for International Settlements, and the Secretariat of the Financial Stability Board, October 2009]</ref>.
====Remuneration and incentives====
The Financial Stability Board's "Principles for Sound Compensation Practices"<ref>[http://www.financialstabilityboard.org/publications/r_0904b.pdf ''FSF Principles for Sound Compensation Practices'', Financial Stability Board, 2 April 2009]</ref>
require that pay levels  should take account of the risks that recipient takes on
behalf of the firm - and not just their short-term profit contributions - and should be monitored and reviewed by boards of governors. Those principles have been integrated into the Basel Committee's  capital framework, and international guidance is under development to reinforce their implementation. The statement of principles by the Committee of European Bank Supervisors, requires the remuneration should be based upon a risk-adjusted combination of the individual's performance and the performance of the unit to which he belongs, and that bonuses should have a deferred component related to longer-term performance<ref>[http://www.c-ebs.org/getdoc/c0ce427e-1abe-445a-8619-5c766cb2de81/CP23.aspx ''Draft high-level principles of Remuneration Policies'', Committee of European Bank Supervisors, 6 March 2009]</ref>.
====Credit ratings====
In response to the shortcomings in the conduct of the credit rating agencies revealed by the [[subprime mortgage crisis]]<ref> See paragraph 3.4 of the article on the [[crash of 2008]]</ref>,
the International Organisation of Securities Commissions (IOSCO) issued a revised code of conduct for credit rating agencies in May 2008 <ref>[http://www.iosco.org/library/pubdocs/pdf/IOSCOPD271.pdf ''Code of Conduct Fundamentals for Credit Rating Agencies'', International Organisation of Securities Commissions, May 2008]</ref>, which are designed to raise the quality of their ratins, and  which contains clauses intended to "manage and mitigate" the conflict of interest that arises from the fact that the agencies receive revenue from the organisations on whose securities they issue ratings.IOSCO have subsequently reported  by that the code had been "substantially implemented" by the three largest agencies – Fitch, Moody’s and Standard & Poors<ref>[http://www.fsa.go.jp/inter/ios/20090318-2/02.pdf. ''Update on Credit Agencies Oversight'', IOSCO, March 2009]</ref>
New legislation creating oversight regimes for credit rating agencies has been approved in Japan and is close to final approval in the European Union; in the United States, amendments to the existing oversight regime had been proposed or already made by September 2009.
====Accounting Standards====
Concern among members of the United States Congress that the ''mark to market'' accounting convention can have a destabilising influence on the financial system has delayed the adoption by the United States Financial Accounting Standards Board  of the International Financial Reporting Standard issued by the International Accounting Standards Board. The G20 Leaders have recommended  that the two  boards should "make significant progress towards a single set of high quality global accounting standards", and the Financial Stability Board has urged them to incorporate a broader range of available credit information than existing provisioning requirements, so as to recognise credit losses in loan portfolios at an earlier stage. In November 2009 The International Accounting Standards Board  issued  an amended version of its standard in an attempt to reach agreement
<ref>[http://www.iasb.org/News/IASB+completes+first+phase+of+financial+instruments+accounting+reform.htm ''IASB completes first phase of financial instruments accounting reform'', International Accountancy Standards Board, 12 November 2009]</ref> and a response is expected from  the Financial Accounting Standards Board .
:''(for more on the mark to market controversy, see paragraph 3.5 of the article on the [[crash of 2008]])''
==Rules versus discretion==
It is generally accepted that regulators will need to be granted a measure of discretion to deal with the range and complexity of the situations they may have to face, but the Warwick Commission has argued that the there will be cases in which the existence of rules would help them to resist political pressures to abandon measures that are unpopular because they have short-term disadvantages<ref name=warwick/>.
==International aspects==
Implementation of macroprudential measures by individual governments may be hampered by the "''[[prisoner's dilemma]]''" consideration that the imposition of unwelcome restrictions may prompt the firms affected to move to a country which has a less restrictive regime. The danger of stalemate can be reduced by international agreement but promises made at "summits" have not always been kept. International agreement is in any case necessary to determine jurisdiction over multinational corporations.
==Costs and benefits ==
==Regulatory structures==
Four types of existing regulatory structure have been identified[http://www.deloitte.com/dtt/cda/doc/content/The%20structure%20of%20Financial%20Supervision.pdf]:
*The institutional approach,  in which a firm’s legal status determines which regulator is tasked with overseeing its activity;
*The functional approach, in which supervisory oversight is determined by the business that is being transacted by the entity  so that each type of business activity has its own regulator;
*The integrated approach,  in which a single universal regulator conducts both safety and soundness oversight and conduct-of-business regulation for all the sectors of financial services business; and,
*The twin peaks approach,  in which  one regulator  performs  safety and soundness supervision function and the other  focuses on conduct-of-business regulation.


The "G30 report" by an eminent international consultative group stressed the need for regulatory  systems with "clearer boundaries between those institutions and financial activities that require substantial formal prudential regulation for reasons of financial stability and those that do not"<ref>[http://www.group30.org/pubs/reformreport.pdf  ''A Framework for Financial Stability'', G30 2009]</ref>. An earlier report by the same international group had concluded that none of the four categories of regulatory structure then in use appeared to offer a significant advantage over the others, and had attributed greater importance to the calibre of their managements. 
==Macroprudential proposals==
The Warwick Commission argued that "macro and micro-prudential regulation require different skills and institutional tructures, and suggested that where possible, micro-prudential regulation should be carried out by a specialised agency (and that) macro-prudential regulation should be carried out ....in conjunction with the monetary authorities, as they are already heavily
involved in monitoring the macro economy"<ref name=warwick/>, and the  de Larosière Group  also stressed the importance of coordination between regulators and central banks<ref name=deL/>.


==Policy decisions==


==Notes and references==
==Notes and references==
<references/>
<references/>

Revision as of 10:22, 15 January 2010

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This editable Main Article is under development and subject to a disclaimer. 
 (The former text of this renamed article has been temporarily transferred to my sandbox to facilitate restructuring
Nick Gardner 16:22, 15 January 2010 (UTC))


Background: Regulatory Failure

Microprudential policy

Pre-crash policy

Post-crash proposals

Leverage

The Turner Review recommended raising banks' reserve ratio requirements to levels substantially above those required under Basel 2 and introducing a discretionary counter-cyclical element that would raise the required ratio during economic booms [1]. The Warwick Commission on international financial reform was also in favour of counter-cyclical regulation but suggested that it should be rules-based to help central banks to resist political opposition to "taking away the punchbowl when the part gets going". Its purpose would be to persuade banks to put away money during a boom-at a time when they would be motivated to run down their reserves[2].

Risk management

The de Larosière Group of European regulators proposed that the board members of banks should be required to abandon the practice of relying upon risk models that they do not understand, and to make fuller use of their professional judgment. [3].

New risk management standards were issued by the Basel Committee on Banking Supervision in September 2008[4].

Derivatives

The rôle of financial derivatives in the crash of 2008 is a topic of controversy among economists. Professor Hyun Song Shin has argued that their use had undermined the stability of the financial system by concentrated risks in the banking system [5], and the eminent economist Joseph Stiglitz has sugqested that major banks should not be allowed to hold derivatives, especially credit default swaps[6], but Professor Myron Scholes has described proposals to ban them as "a luddite response". The regulatory authorities do not appear to be considering a ban on their use, but they are formulating measures to improve their ability to monitor them. The United States Department of the Treasury has proposed legislation to require clearing of all standardized over-the-counter derivatives through regulated central counterparties who must impose robust margin requirements and risk controls [7], and similar measures are considered in a European Commission consultation paper on possible derivatives legislation[8] that may be expected to be discussed in forthcoming meetings of an international regulators forum[9]

Off-balance-sheet vehicles

The international Financial Stability Board has issued new disclosure standards for off-balance sheet vehicles, and has recommended the imposition of higher capital requirements where appropriate.


Macroprudential proposals

Notes and references

  1. ↑ The Turner Review: A regulatory response to the global banking crisis, Financial Services Authority, March 2009
  2. ↑ The Warwick Commission on International Financial Reform: In Praise of Unlevel Playing Fields, (The report of the second Warwick Commission) University of Warwick, November 2009
  3. ↑ The de Larosière Report (Report of the High-Level Group on Financial Supervision in the EU, European Commission, February 2009
  4. ↑ Principles for Sound Liquidity Risk Management and Supervision, Basel Committee on Banking Supervision, September 2008
  5. ↑ C Securitisation and Financial Stability, Vox 18 March 2009
  6. ↑ Ben Moshinsky: Stiglitz Says Banks Should Be Banned From CDS Trading , Bloomberg October 12 2009
  7. ↑ Regulatory Reform Over-The-Counter (OTC) Derivatives, US Department of the Treasury, May 13 2009
  8. ↑ Possible initiatives to enhance the resilience of OTC Derivatives Markets, (Consultation Document), European Commission, 3 July 2009
  9. ↑ A Global Framework for Regulatory Cooperation on OTC Derivative CCPs and Trade Repositories, Banque de France, September 24, 2009
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