As we discussed in a blog post earlier this summer, the Canadian Securities Administrators released a consultation paper in June that proposed a framework of rules for the reporting of OTC derivatives transactions and the operation of trade repositories.

Earlier this week, the International Swaps and Derivatives Association published a comment letter in response to the CSA's paper. Of particular interest, ISDA comments on some of the challenges in implementing a regime for mandatory reporting to trade repositories. It highlights some of the changes that have been made under the proposed U.S. regulations to facilitate foreign regulator access to U.S. based repositories which make the establishment of a single global trade repository for each asset class of derivatives a more palatable option for regulators. The comment letter also addresses block trade exception rules and the issue of real-time reporting of trade information.