RESPONSE OF BNP PARIBAS

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1 Paris, March 1, 2011, Public consultation on Central Securities Depositories (CSDs) and on the Harmonisation of certain aspects of securities settlement in the European Union RESPONSE OF BNP PARIBAS to the Consultation document of the Services of the Directorate-General Internal Market and Services Name and address of the respondent BNP Paribas S.A. 3, rue d Antin Paris - France EC Interest Representative Register ID: Field of activity of the respondent BNP Paribas Group ( is a European leader in banking and financial services, with a significant and growing presence in the United States and leading positions in Asia. The Group has one of the largest international banking networks, a presence in over 80 countries and over 200,000 employees including: nearly 165,000 in Europe - among whom 18,900 in Italy, 18,000 in Belgium, 64,600 in France and 4,000 in Luxembourg. BNP Paribas enjoys key positions in Corporate and Investment Banking, Private Banking & Asset Management, Insurance, Securities Services and Retail Banking. 1

2 Central Securities Depositories regulation Key points for harmonisation As it currently stands, the CSD regulation will lead to fragmentation: more CSDs will be created in the near future. This is detrimental to the efficiency of the post trade market. Fragmentation will namely occur on the notary function, which remains a key function for any CSD who want to settle trades on given securities in its books at the lowest possible cost. Importability and exportability will result in two laws being applicable to the issuance: (i) the law of the issuer will apply to the creation of the securities and (ii) the law of the CSD will apply to the entrance into the intermediated holding system. In order to overcome this, CSDs will attract issuers by opening branches in the countries where the targeted issuers are located. In addition, since the future regulation doesn t distinguish CSDs and ICSDs, we fear increased risk resulting from the uniform regulation, where CSDs are to develop custody services, thus creating new risks. The purpose of the future CSD regulation should be to regulate the future CSD market. That market is undergoing considerable changes, mainly due to the introduction of T2S. However, the extent of those changes is unforeseeable. It is not desirable to consider the current CSD landscape and to regulate that. We think the CSD regulation should be flexible enough to allow changes. More importantly: we think that CSDs should be regulated from a risk perspective. Future evolutions will take place, but the systematic infrastructures that CSDs are should not be allowed to take risks, which are not inherent to their functions. And the infrastructure functions need to be ring-fenced against other types of risks. The objective of the following points it to address problems related to fragmentation, and risk. 1. The CSD Regulation should address only the infrastructure functions. Where a CSD is approved to fulfil the functions of a CSD (notary function and central settlement function), it may fulfil only those functions. If the regulation allows CSDs to extent their business to commercial services, those entities will enter into competition with the banking services providers of the post-trade market, which is already a highly concentrated and competitive market. We fear a considerable increase of risk at the level of the infrastructures that CSDs are. The CSD should be a risk-free environment. The entity that fulfils these functions, should not, ipso facto, be authorised to fulfil any other functions (currently referred to as ancillary functions ). Such other functions include banking functions. Even if those banking functions were limited to operations, which are related to infrastructure functions, they can amount to considerable credit exposure. A risk-free environment means that the CSD should not be allowed to take any other forms of risk that the ones that are inherent to their activity, i.e. operational risk. Where a CSD wants to enter into additional types of services, related to its CSD activities, it may do so on a strictly segregated basis. Commercial services, such as credit functions or issuers services must be incorporated distinctly from the legal entity, which provides the CSD functions. In addition, each entity must have it s own resources. We need to ensure that the CSD functions will be protected against any going concern occurring on those commercial services. 2

3 There is in principle no obstacle to have within the same group an entity providing CSD functions and another entity offering those commercial activities, provided that those segregation rules are implemented. The participants to the infrastructure must not be obliged to pay for the development of a bank. 2. The infrastructure functions are notary function and central settlement function. The notary function ascertains the entrance of all or part of the issuance in the intermediated holding system. It therefore comprises the relationship with the issuer or with registrars, who deposit all or part of an issuance with a CSD. That issuance that the CSD accepted is than exactly reflected by the credit of securities to securities accounts that the CSD maintains for its participants. This corresponds to the activity account provider under the SLD. The Central Settlement Function is the operation of a securities settlement system as under the Settlement Finality Directive. 3. Authorisation and passporting As long as the CSDs are limited to infrastructure functions, they should be authorised in their home Member State and a full passporting regime should be applicable. Authorisation and passporting apply to both functions together, not to each function distinctly. In practice, the passporting would not apply on the central settlement function. Not only is the central settlement in many cases out-sourced to T2S, but mainly: settlement in a given security will take place in a given CSD, only if the issuer of that security entered it into the intermediated holding system with that CSD. Example: A CSD in country A will centrally settle securities created and issued in country B, only if the issuer issued the securities with that CSD. If the issuer has issued the securities only with the CSD of country B, settlement can take place with the CSD of country A, only if that CSD acts as global custodian. Passporting on the notary function (removal of barrier 9) means that issuers may elect to enter the issuance in any CSD in the EU and that CSD anywhere in the EU may accept issuances from any issuer. This still creates some problems related to corporate law, which needs to be taken into account. 4. Harmonisation Harmonisation is necessary in order to smoothly process cross-borders transactions. The main fields, which need an harmonisation are: Market disciplines: rights and duties of the participants have to be the same in all the European countries (i.e.,best practices, same penalties to be applied...) Fair access to the local markets : in some European countries, as Spain, a foreign bank is not allowed to directly access the CSD. This is not compliant with a free access in all the T2S countries We also need to have a common definition of what a settlement fail is, in order to work on the same scope. The number of settlement fails needs to be reduced through appropriate measures, but these measures should not add risks or create non STP process. 3

4 We are in favour of a harmonised T+2 settlement cycle, which would facilitate corporate actions processing. Harmonisation of settlement cycles should concern trades executed on a regulated market only. The introduction of the harmonised T+2 settlement cycle should be aligned on the go-live date of T2S. Part 1: Appropriate regulatory framework for CSDs 1. Scope and definitions 1.1 Personal scope and exemptions 1. What is your opinion on a functional definition of CSDs? We disagree with the functional definition of CSDs. We are in favour of defining CSDs by in institutional approach: a legal entity that provides one or more core functions (as discussed under question 3 hereafter) should be subject to the future CSD regulation. This does not prevent a CSD to distinctly incorporate a legal entity that could provide additional services such as securities lending and borrowing or financing. 2. What is your opinion of the possible legislation and providing for any exemptions (such as central banks, government debt offices, transfer agents for UCITS, registrars, account operators)? Although we take the view that same functions should be subject to same regulation to provide for a level playing field, we agree to narrowly defined exemptions, essentially for central banks and government agencies. 1.2 Definition of CSD services Background 1.3 Core CSD services 3. What is your opinion on the above description of the core functions of a CSD? We agree with the definition of central settlement function. We disagree with the definitions of central custody function and notary function. We think that these 2 functions should not be separated: CSDs only fulfil the central custody function because they operate the notary function. The CSD ensures that any traded securities - be it via exchanges, trading platforms or over the counter - exist and that transfers are duly effected. In order to ensure the existence of securities, CSDs reconcile (i) the part or entirety of the securities of the same description that the issuer, either directly of via registrars, deposited with the CSD and (ii) the aggregate of the securities of that description that the CSD credits to the securities accounts of its participants. The notary function could be defined as follows: Establishing and maintaining a system of initial bookkeeping that records the amount of each issue in the system in a specific account in the name of the issuer; that enables securities 4

5 transactions to be processed by book-entry and the maintenance of securities accounts for the account of participants to the aggregate of which are credited an identical number of securities of the same description as the CSD maintains in the system of central booking. 4. Which core functions should an entity perform at a minimum in order to be qualified as a CSD? Since both core-services as described in the response to question 3 are central infrastructure functions, be believe that, where an entity wishes to provide either of them, the future CSD regulation should apply to that entity. The same is true if the notary-function were separated between a notary function and a central custody function. Once approved, the CSD should have the possibility to provide both core functions (subject to compliance with the Settlement Finality Directive concerning the Central Settlement Function). 5. Should the definition of securities settlement systems be reviewed? We have encountered no practical difficulties resulting from the current definition of a Securities Settlement System. 1.4 Ancillary CSD services 6. What is your opinion of the above description of ancillary services of a CSD? Is the list above comprehensive? Do you see particular issues as to including one or several of them? The undertaken CSD regulation and T2S will cause considerable, but currently unknown, changes in the CSD landscape in the coming years. We urge the European Commission to regulate CSDs from a risk perspective only, ring fencing the identified core-functions against any other types of risk. This should not prohibit the provision of other types of services under stricter conditions. The European Commission proposes an open-ended enumeration of ancillary functions, some of which are banking services and require considerable amounts of (intraday) overdrafts and settlement in commercial bank money, which must meet four criteria: - a low-risk business model of CSDs, - ancillary functions must have a clear connection with the core-functions, - the activities of existing CSD must be taken into account and - the enumeration of ancillary functions is flexible. The definition of a clear connection with the core-functions is not clear and that criterion is not connected to the risk-exposure of the CSD. Even if an ancillary function has a clear connection with a core function, the credit exposure could still be very high. In our view, ring fencing the infrastructure functions of a CSD can be achieved by the incorporation of the ancillary services into a distinct legal entity that has its own resources. 5

6 Where necessary, that distinct legal entity must comply with Directive 2006/48/EC relating to the taking up and pursuit of business of credit institutions. The practical consequences would be two-fold. First, it means that the future CSD legislation should not allow CSDs to provide ancillary functions and it should expressly provide that if a CSD is licensed under the CSD regulation, it may not be licensed under the Directive 2006/48/EC. Second, it means that where a CSD wishes to expand its business by providing global custody services to its participants (so-called investor CSD services), it should do that in a distinct legal entity. That entity should benefit from the entirety of possibilities offered by Directive 2006/48/EC. 2. Authorisation and ongoing supervision of CSDs 2.1 Background 2.2 Domestic and non-domestic activities of a CSD 7. According to you, could the abovementioned cases impact a future regime of authorisation and supervision? Yes? No? No opinion? Please explain why. Are there other cases, which could have an influence on a future regime of authorisation and supervision? The future regime of authorisation and supervision mainly depends on the functions that a CSD may fulfil. - If a CSD is authorised only to provide core services, as we described in our answer to question 6, the authorisation and supervision regime could be flexible since the activities of a CSD imply no credit risk and are harmonised. - If a CSD is authorised to provide the ancillary functions too, we are against pasporting. We would like to make the following comments on the enumeration under paragraph 2.2 of the consultation document. - The issuance of securities by an issuer from a different jurisdiction that the CSD should be authorised service by the jurisdiction of the issuer and of the CSD; - The participation of a member from a different jurisdiction to the settlement function operated by the CSD does not influence on the authorisation and supervision regime; - Operations related to group structures (opening branch, subsidiary and mergers): the branch, subsidiary or merged entity must be authorised in the country where it is established. This means that, where a CSD located in jurisdiction A opens a branch in jurisdiction B, the headquarter is authorised and supervised by the supervisory authority of jurisdiction A and the branch by that of jurisdiction B ; - The conclusion of access and interoperability arrangements between CSD and/or other financial markets infrastructures should be authorised by the supervisors of all involved entities; - We are strongly in favour of settlement in Central Bank Money, unless it is strictly impossible. For example: the settlement in a currency different from the currency of 6

7 the Member State of the CSD: as long as central banks do not allow access to their currencies to entities that are not established on their territories, settlement in currency denominated securities takes place in commercial bank money, via a settlement bank or not; - Performing settlement through a common IT platform between CSDs of different Member States does not influence on the authorisation and supervision regime since the common IT platform insources the securities settlement system s technical functionalities, which remain of each CSD s responsibility. None. 2.3 Initial authorisation procedure 8. What other elements should be submitted as part of the initial application procedure by a CSD? 9. According to you should the authorisation procedure of a CSD be distinct from the designation and notification procedure under Art. 10 of the SFD? Yes? No? No opinion? Please explain why. Yes, it should be distinct, since there is not always a correlation between a Securities Settlement System and a Central Securities Depository. In addition, article 10 of the SFD provides that Member States determine which systems are to be included in the scope of the SFD. We do not think that this is appropriate for the future CSD regulation, applicable to CSDs. 2.4 CSD Register and temporary grandfathering 10. What is your view on establishing a register for CSDs? We are in favour of such a register, detailing the functions that each CSD fulfils. 11. What is your view on the above proposal for a temporary grandfathering rule for existing CSDs? We are against the principle of grandfathering. The reason for this is that the future CSD regulation and T2S will drastically transform the CSD landscape. The evolutions that will take place are currently unknown. It is therefore important that all CSDs are approved according to the future Central Securities Depositories Regulation. Alternatively, we can leave the CSDs a six months adaptation period. 2.5 Capital requirements 12. According to you, does the above approach concerning capital requirements, suit the diversity of CSDs? Yes? No? No opinion? Please explain why. The approach concerning capital requirements does not suit the existing diversity of CSD. The (I)CSD that provide banking services have a banking license today. 7

8 Considering the future CSD market: - If CSDs are defined as entities that fulfil only the core-functions, the capital requirement can be relatively low and CSD don t need to be licensed credit institutions, given that CSD, per se, don t take any credit risk. A CSD that wishes to provide banking services, must incorporate the bank distinctly and that distinct entity should apply for a banking license; - If CSDs are defined as entities that, per se, may also provide the so-called ancillary functions, the adoption of a lump sum should be suitable. CSD offer various types of services, but the same is true for banks, which are all submitted to a minimum capital requirement under Directive 2006/48/EC. 2.6 Supervision 13. According to you, should the competent authorities have the above-mentioned powers? Yes? No? No opinion? Please explain why. Yes, since it fits the particular nature of CSD. 2.7 License (passport regime) 14. Would a special purpose banking license be appropriate for banking type services? No, we think that if a CSD wishes to provide banking services, those banking services should be distinctly incorporated and that distinct legal entity should have its own resources. 15. Which of these three passporting options would you support? Full passporting? Limited passporting? Opt out regime? Please explain why. We support a full passporting regime for CSDs that provide only the core-functions. Where a legal entity provides ancillary functions (but not the core-functions), the passporting regime of Directive 2006/48/EC should apply. If the future regulation allows that a same legal entity provides CSD core-functions and ancillary functions, no passport should apply. 3. Access and interoperability 3.1 Background 3.2 Access of market participants to CSDs 16. What is your opinion about granting a right for market participants to access the CSD of their choice? As is currently already the case, we think that market participants should have a nondiscriminatory access to CSDs. CSDs should apply transparent fees. 8

9 If a CSD, or a legal entity of the same corporate group of the CSD, acts also as participant by providing local or global custody services related to securities, which are not issued with that CSD, that competition should be on fair. This is achieve by price transparency, distinct incorporation and own resources for the CSD and the entity that provides banking services. 3.3 Access of issuers to CSDs 17. What is your opinion on the abolition of restrictions of access between issuers and CSDs? We are in favour of the abolition of restrictions of access between issuers and CSDs. This will raise some consequences, which need to be addressed. First, it must be clear that the relation between the issuer and the investor remains governed by the corporate law of the Member State where the company has its registered office; and the relation between the CSD and its participants by the law of the Member State where the CSD holds the relevant securities account for the participant. Second, the split of an issue under a single ISIN code should not be permitted. The reason for this is that investors can (indirectly) invest via both CSD and concentrate their securities with a single account provider. This could create difficulties in the reconciliation process. Thirds, the split of an issue is acceptable, under two different ISIN codes, if the issuer wants to split the issuance. The split of the issuance should not be imposed upon issuers by CSDs. Fourth, since in some EU jurisdictions, securities are not issued in immobilised or dematerialised form, it is of utmost importance that dematerialisation is encouraged so to facilitate the removal of barrier According to you, should the removal of barrier 9 be without prejudice to corporate law? Yes? No? No opinion? Please explain why. The removal of barrier 9 should be without prejudice to corporate law. The CSD should adapt to the issuer s company law, i.e. the law of the Member State where the company has its registered office. 19. How could the integrity of the issue be ensured in the case of a split of an issue? In case of a split of an issue, creating two distinct ISIN codes (one for each CSD) can ensure the integrity of the issue. The intervention of a common depository can also ensure the integrity of the issue, but this is a costlier solution that the creation of two distinct ISIN codes. 3.4 Access and interoperability between CSDs 20. What is your opinion on granting a CSD access rights to other CSDs and what should their scope be? 9

10 Access from one CSD to another CSD concerns either the notary (and central custody) function or the central settlement function. - As concerns the notary function: the joint exercise of the notary function, and therefore of the central custody of the corresponding custody accounts for the CSDs participants is possible only if the issue is split between the CSD. This has been discussed under question 19; - As concerns the Central Settlement Function: this will be largely outsourced to T2S. Otherwise, we don t see how the Central Settlement Function can be shared between two CSD if they are not both issuer-csd for a par of the issuance. The co-called investor-csd activity consists, for a CSD, to accept that securities, which are not issued with that CSD, are credited to the securities accounts that the CSD maintains for its participants. For those securities, the (investor) CSD is a participant to the issuer-csd, just like any other market participant (section 3.2 here above). Investor-CSD services are the same type of services as global custody. Those services mean that the investor-csd takes credit risk on its clients (otherwise competition with global custodians, which are banks, is not possible). For this reason, the investor-csd functions are part of the ancillary functions and should be incorporated distinctly from the core-functions that that CSD provides. They imply important risks. We have the following detailed comments: - Reinforced legal assessment: this concerns property and guarantee law. Concerning the guarantee law, the Financial Collateral Directive contains a well functioning conflict of law rule, which brought great legal certainty. Concerning the property law, this should be covered by the future Securities Law Directive; - Omnibus accounts: each CSD, operating in its own legal environment, uses omnibus accounts or segregated accounts. The future CSD Regulation does not need to regulate this; - Access arrangements: since CSD are infrastructures, the access to CSD should be transparent. This is true for market participants and for CSDs, where one CSD acts as a investor-csd, i.e. global custodian; - Moment of finality and irrevocability: this should be harmonised for all CSDs participating to T2S; - Provisional transfers: we entirely agree that provisional transfers should be prohibited, but we are not certain whether the future CSD regulation is the right momentum to do that; - Harmonisation of securities account structures: The future CSD Regulation does not need to regulate this; - Credit extensions: this is an ancillary function and it should therefore be incorporated distinctly; - Intraday DvP settlement: we entirely agree, but the future CSD Regulation is maybe not the right momentum to regulate this; - No increase of liquidity risk: this is related to an ancillary function and it should therefore be incorporated distinctly; - Right of access: since CSD are infrastructures, the access to CSD should be transparent. This is true for market participants and for CSDs, where one CSD acts as a investor-csd, i.e. global custodian; 10

11 - Remuneration: since CSD are infrastructures, the access to CSD should be transparent. This is true for market participants and for CSDs, where one CSD acts as a investor-csd, i.e. global custodian; - Specific authorisation: this is already covered in section 2.6; - Cooperation between authorities: this is addressed under question 7; - Prohibition of cherry picking arrangements. 3.5 Access between CSDs and other market participants 21. What is your opinion on a CCP s right of access to a CSD? We agree in principle that CCPs should have a right of access to the CSD. However, this right should be conditional on: the CCP meeting the membership requirements of the CSD; the CCP having the approval of its users to request access; the CCP paying for any additional costs in establishing a link with the CSD; and the CSD granting the link on the basis of nondiscrimination, with transparent membership criteria and explicit pricing. A refusal of access should only be based on risk related criteria or exemptions to access rights as detailed in MiFID. In our opinion, detailed requirements relating to the data exchanged should be a matter for agreement between the CSDs and the CCPs and users where applicable. It is essential that the CCP and the CSD make relevant arrangements for the flow of information to fulfil any regulatory obligations and that any link should not have a detrimental effect on risk management standards and settlement efficiency at either entity. 22. What is your opinion on access conditions by trading venues to CSDs? Should MiFID be complemented and clarified? Should requirements be introduced for access by MTFs and regulated markets to CSDs? Under what conditions? We advocate user choice between competing CSDs and therefore agree in principle that trading venues (both Regulated Markets and MTFs) should have a right of access to CSDs. However, this right should be conditional on: the trading venue having the approval of its users to request such access; the CSD receiving the access-request establishing a link with the CSD already used by the trading venue (to allow the settlement of transactions between trading venue members that are participants in the different CSDs); trading venue members authorizing the CSD receiving the access request to accept instructions on their behalf; and the CSD receiving the access request and trading venue making arrangements for the flow of information to fulfill regulatory obligations (e.g. on settlement status reports). 23. According to you, should a CSD have a right to access transaction feeds? Yes? No? No opinion? Please explain why. We advocate user choice between competing CSDs and therefore agree in principle that CSDs should have a right of access to transaction feeds. However, this right should be conditional on: the CSD having the approval of its users to request access; the access-requesting CSD establishing a link with the incumbent CSD (and CCP where used); trading platform members authorizing the access-requesting CSD to accept instructions on their behalf; and the access- 11

12 requesting CSD and trading platform making arrangements for the flow of information to fulfill regulatory obligations (e.g. on settlement status reports). 24. What kind of access rights would a CSD need to effectively complete with incumbent providers of CSD services? Should such access be defined in detail? To effectively compete with the incumbent CSD, the access-requesting CSD must be given non-discriminatory access to the transaction feed and the right to establish appropriate links with the incumbent CSD (and CCP where used). 4. Prudential rules and other requirements for CSDs 4.1 Background 4.2 Legal framework 25. Do you think that the legal framework applicable to the operations performed by CSDs needs to be further strengthened? Further strengthening of the legal framework for operations performed by CSDs appears desirable for the purpose of achieving perfect interoperability and absolute compatibility (as notions such as 'timing of entry' and 'irrevocability of instructions' should be identical across the European Union, without any room for national variations). 26. In particular should all settlement systems operated by CDSs be subject to an obligation of designation and notification? Yes, all systems should be notified. 27. What do you think of the general elements of these requirements, particularly with respect to the obligation for CSDs to facilitate securities lending and the obligation of counterparties to securities loans to put in place adequate risk controls? We are not in favour of obliging CSD to put in place securities lending facilities. Some CSDs already have securities lending and borrowing programs in place. Some market participants offer the same types of services to their clients. Securities lending and borrowing programs are among the incentives to reduce settlement defaults. 28. What do you think about the requirement for issuers to pass their securities through a CSD into a book entry form? If such an obligation were considered, which securities should it concern? Only listed securities? All securities with an ISIN code? Only equities? Eligibility approach? We are strongly in favour of dematerialisation of all securities that are admitted to the operations of a CSD. 29. What is your opinion with respect to grandfathering? We are not in favour of the grandfathering clause as described. 12

13 In our view, a grandfathering clause would grant issuers of non book-entry securities issued before a given date a certain period of time to convert them into book-entry securities. 30. What do you think about the requirements above for DvP? Do you see any issues in respect of the different DvP models? In general believe that DvP should be encouraged - the 1991/92 CPSS IOSCO definitions are already largely used by most CSDs and this good practice should continue to be encouraged. The principle should be that DvP is final when both securities delivery and cash payment are final. Night time settlement is compatible with DvP priciple; therefore CSD legislation should not prevent night time settlement, as this is more efficient and does not add more risk. We take the view that reference to FoP is not relevant to a discussion on DVP. FOP is not an exception to DvP but a different transaction type and participants should have a right to settle FoP. We recommend to focus on principles in the CSD legislation and to deal with technical details at level 2 or What are your particular views on the grandfathering principle couples with the requirement for the introduction of a guarantee fund? Most if not all European CSD already have a DVP model, so it's questionable whether a grandfathering is required at all. As DVP is a core principle in risk management, in our view there should be no grandfathering. Consequently there should be no guarantee fund requirement as no such fund is required in a DVP model. 32. What do you think about a preference of settlement in central bank money? Should such a preference be applied to all types of securities? We are strongly in favour of settlement of the cash leg in central bank money. This should be applied to the settlement of all transactions on securities that are admitted to the operations of a CSD. 33. Do you think that the principles outlined above could be transposed in future legislation? Some principles outlined under section 4.6 could be transposed in future legislation. We are in favour of a system where settlement always takes place in central bank money, except if the securities, admitted to the operations of the issuer-csd, are denominated in a currency other than the currency of the Member State where the CSD is located. Only in the latter case, settlement can take place in commercial bank money, whether in the books of that CSD of in the books of a payment bank. It is important to stress in this context that so-called investor-csds are global custodians. They can internalise settlements of securities, which are primarily listed with another CSD. Since this is global custody, this should fall out side the scope of the CSD Regulation. 13

14 As a consequence, we find difficult to understand the 3 rd bullet point of section 4.6 ( where both central and commercial bank facilities are offered,... ). The reason for this is that there never is a choice between commercial bank settlement or central bank settlement. Settlement always takes place in central bank money, except when this is impossible and the conditions for settlement in commercial bank money are met. 34. What is your opinion about the extent of the requirements that should be imposed when commercial bank money is used? 4.7 Reconciliation and protection of customers securities 35. What do you think about the above rules? We fully agree with these rules. No. 36. Are further rules needed in order to ensure reconciliation and segregation? 4.8 Operational risk controls 37. Do you think that these six basic principles cover sufficiently operational risks? We suggest adding the requirement for adequate insurance and risk transparency to its participants. We are unclear of what is meant by heavy equipment in the second paragraph of 4.8. and propose to replace information by sensitive information. In the fifth bullet we suggest to specify: operational risks. 4.9 Governance 38. What do you think about the eight principles above, particularly with respect to board composition and the need for a risk committee? We fully agree with the first seven principles. Concerning the risk committee, this should not be necessary for CSD that do not provide any banking services. If the future CSD regulation allows CSDs to provide banking services, as part of ancillary services, the risk committee is necessary as per EMIR Outsourcing 39. According to you, should CSDs be subject to a principle of full responsibility and control on outsourced tasks? Yes? No? No opinion? Please explain why. Yes, given the systemic nature of CSDs and the importance of possible outsourced tasks (IT) for the functioning of the CSD, the CSD should be fully responsible for outsourced tasks. 14

15 40. Should there be any other exemptions from the principle of responsibility and control of CSDs on outsourced tasks? The proposed exceptions are the only acceptable ones. In principle, any exceptions should be subject to approval by the local competent authorities of the CSD. T2S cannot be mandated, and should not form an explicit part of CSD legislation. The T2S platform should fall under those exceptions. 41. What is your opinion on the above prudential framework for risks directly incurred by CSDs? The future CSD legislation should focus on the ring-fenced functions. Should the CSD decide to offer additional services these should be subject to distinct incorporation and that distinct legal entity is subject to existing authorisation, regulation and supervision. In particular, on extension of credit point in (b), that distinct legal entity should be subject to banking rules. 42. What do you think about the principles above? We are unclear about the relevance of these principles against the background of our principal position that distinguishes between the ring-fenced functions and ancillary services and the respective regulations and supervision. 43. What do you think about including these elements of the Code in legislation? We support the inclusion of the elements of price transparency and service unbundling in future CSD legislation to provide for continued availability. The same rationale makes us advocate the inclusion of these elements in EMIR and MiFID as trading venues and CCPs have also signed the Code. PART II: HARMONISATION OF CERTAIN ASPECTS OF SECURITIES SETTLEMENT IN THE EUROPEAN UNION 44. According to you, is the above described harmonisation of key post trade processes important for the smooth functioning of cross-border investment? Yes? No? No opinion? If yes, please provide some practical examples where the functioning of the internal market is hampered by absence of harmonisation of key post trading processes. If no, please explain your reasoning. The management of cross-border transactions is currently a very manual process. Indeed, all the local rules of the receiving country have to be followed in order for the securities to be accepted. All the back offices have to carefully monitor those transactions, and have to manage as many specific national processes as European countries (1 process per market). In this situation, we consider that a harmonisation is necessary in order to smoothly process cross-borders transactions. The main fields which need a harmonisation are: 15

16 Market disciplines: the right and duties of the markets participants have to be the same in all the European countries (i.e. common best practices, common penalties to be applied ) A fair access to the local markets: currently some European countries do not accept foreign participants to open an account in their CSD (i.e. Spain). This is not compliant with a free access in all T2S countries, and does not create a level playing field. The settlement finality of the transactions: all European markets have to consider the irrevocability of the settlement transactions at the same time to avoid any discrepancy in the rights attached to the securities. 45. Do you identify any other possible area where harmonisation of securities processing would be beneficial? See our response to question SETTLEMENT DISCIPLINE 5.1. Background for improving and harmonising settlement discipline The broadly agreed definition of "Settlement discipline" points in the direction of a regime, typically run by a CSD and including agreed market standards (or practices), with the aim of achieving timely matching and settlement of securities transactions. There is a common expectation among market participants that settlement processes should function smoothly and in a foreseeable way. Future legislation could tackle the issue of improving settlement discipline in the European Union. This would be in line with the proposed regulation on short selling. Strong settlement discipline rules could be in place in order to ensure the timely matching and settlement of transactions in financial instruments. A high degree of settlement discipline has at least three advantages: It reduces the counterparty risk, or more specifically liquidity risk and replacement risk, which exists between the trade and settlement dates; It reduces the overall costs to all participants of settlements by maximising operational efficiency and reducing liquidity costs to handle exemptions (such as fails), thus contributing to overall market efficiency and stability; And it contributes to the fairness of the financial markets as it encourages equal treatment and behaviour by all market participants. In particular in an increasingly cross-csd environment the existence of non-harmonised national discipline regimes may imply that regulatory arbitrage takes place: i.e. Market participants may re-direct settlement volumes between CSDs due to "softer" discipline and penalty regimes. Settlement fails can have different causes. Failed communication can occur all along the chain of communication between trade and settlement. The risk of failed communication can be reduced through highly standardized communication systems, e.g. systems that automatically capture all relevant trade details for participants. Other causes can be operational failures, such as computer errors or system breakdowns. Most settlement fails occur because of a seller s inability to deliver securities it expected to receive from an unrelated transaction, which can lead to a daisy chain of settlement fails. A final reason for fails can derive from a 16

17 short selling strategy, where a seller sells a security it does not own, and where there are insufficient incentives to avoid a failed settlement by borrowing it to make delivery. The following four areas could be foreseen for establishing common EU rules on settlement discipline: Early matching of settlement instructions Early settlement on intended settlement date (ISD) Prevention of fails management Settlement of fails after ISD 5.2. Definition of settlement fails 46. According to you, is a common definition of settlement fails in the EU needed? Yes? No? No opinion? Please explain why. If yes, what should be the key elements of a definition? Yes, a common definition of what is a settlement fail is needed in the EU, in order to work on the same basis. The implementation of common settlement disciplines can only be done should the countries have adopted the same definition of what is a settlement fail and what is not and thus should not be impacted by the common settlement disciplines. For instance, in the case of a settlement chain, only the 1 st defaulting participant should be penalised, as the other defaulting participants failed because of him (should they have been creditor (in securities or cash) with the incoming receipt) Scope of a harmonised regime on settlement discipline 47. According to you, should future legislation promote measures to reduce settlement fails? Yes? No? No opinion? If yes, how could these measures look like? Who should be responsible for putting them in place? If no, please explain. Yes, the future legislation should promote measures to reduce settlement fails. The major reason for implementing market disciplines is indeed to reduce the settlement fails. On another hand, such measures should not add risks in other fields as well as not create non STP process. The CSDs should be the ones responsible for putting them in place and carefully monitoring them, in a STP manner Ex ante measures for settlement discipline 48. What do you think about promoting and harmonising these ex-ante measures via legislation? Yes, legislation has to promote and harmonise ex-ante measures. It is true for the use of the pre-matching procedures, the use of STP technology, the use of common ISO standards but has to be carefully addressed when concerning the early settlement and early matching, as 17

18 there is no common settlement cycle currently in Europe, and the differences in time zone have to be kept in mind. Most of the European participants have US or Asian clients, and these differences in time zones have to taken into account in the definition of the early matching and early settlement Ex post measures for settlement discipline Regarding ex post rules against settlement fails, future legislation may contain high level rules on a harmonised penalty regime as well as harmonised enforcement rules such as buy-ins and cash-compensation rules. This legislative approach could build on article 13 of the Proposal for a short selling regulation adopted by the Commission of 15 September 2010 which foresees specific measures arising from patterns that factor in late settlement into a trading strategy. The scope of this article 13 is limited to shares or sovereign debt admitted to trading on a trading venue, i.e. a regulated market or an MTF in the European Union. One approach would be to extend the scope of application of Art. 13 both in terms of financial instruments and in terms of trading venues covered. 49. What do you think about promoting and harmonising these ex-post measures via legislation? Yes, legislation has to promote and harmonise ex-post measures. Some of these measures could oblige some markets to review their national regulatory landscape. 6. HARMONISATION OF SETTLEMENT PERIODS 50. According to you, is there a need for the harmonisation of settlement periods? Yes? No? No opinion? Please explain why We are in favour of a harmonisation of settlement cycles in Europe on T In what markets do you see the most urgent need for harmonisation? Please explain giving concrete examples. The need for harmonisation is more urgent in the countries that wish to join T2S, as it will ease the corporate actions management for example. The exhaustive list of countries joining T2S is not known for the moment. 52. What should be the length of a harmonised period? Please explain your reasoning 18

19 We are in favour of a harmonisation of settlement cycles in Europe on T+2. The ideal harmonised period has been studied in a dedicated group called the Harmonisation of Settlement Cycles Work Group. The conclusions of this working group studies have to be the driver for the decision on the length of the harmonised period. Settlement periods are usually set by trading venues. Any future legislation would have to decide what types of trading venues should be included, e.g. regulated markets, MTFs or other organised platforms. 53. What types of trading venues should be covered by a harmonisation? Please explain your reasoning The legislation should focus on securities regulated market, but for all instruments and all transactions types, knowing that the off exchange should naturally follow the same trend, while keeping the possibility to shorter the settlement cycle if needed for specific processes. For instance, in order to prevent a short selling, a shorter cycle could be used to cover a position via the use of a lending of securities. Another issue concerns the scope of future harmonisation, i.e. which types of financial instruments and transactions should be covered. Already today, some markets are able to settle faster than the standard settlement period. In order not to hamper highly efficient settlement structures, future legislation should give sufficient room for transactions to settle at shorter periods. 54. What types of transactions should be covered by a harmonisation? Please explain your reasoning Cf. our answer to question What would be an appropriate time span for markets to adapt to a change? Please explain After a high level study, participants require a timeframe between 12 to 18 months in order to adapt to a new settlement cycle. Whereas a change of settlement cycle is not such a consequent project in the technical systems, it is much more impacting on the operational side. A change would require reviewing the back-offices processes and procedures; the contracts with the clients; to potentially improve STP. All these things require sufficient time in order to be put in place effectively. We propose that the legislation proposes an explicit deadline for implementation in order to facilitate awareness of all industry participants. 7. SANCTIONS 56. According to you, how should the principles examined in the communication on sanctions apply in the CSD and securities settlement environment? 19

20 To avoid distortions of competition, in particular in the context of the removal of Barrier 9 (see our answers to Q 17 and 18), we advocate the application of the envisaged harmonisation of sanctioning regimes. 20

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