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Template:Art 15 SFTR disclosure document: Difference between revisions
Template:Art 15 SFTR disclosure document (view source)
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This is the regulatory initiative that, so say some commentators, nearly caused the [[boredom heat death]] of the universe when a well-meaning [[torpidity]]<ref>A [[torpidity]] is the [[collective noun]] for a group of [[industry association]]s. True.</ref> of [[industry association]]s produced a [[Media:SFTR-information-statement.pdf|5,000 word disclosure document]] explaining to seasoned industry professionals (whom you would think would already know) what was meant by the expression “[[title transfer]]”. | This is the regulatory initiative that, so say some commentators, nearly caused the [[boredom heat death]] of the universe when a well-meaning [[torpidity]]<ref>A [[torpidity]] is the [[collective noun]] for a group of [[industry association]]s. True.</ref> of [[industry association]]s produced a [[Media:SFTR-information-statement.pdf|5,000 word disclosure document]] explaining to seasoned industry professionals (whom you would think would already know) what was meant by the expression “[[title transfer]]”. | ||
This is mandated by Article 15 of [[SFTR]]. Firms engaging in such fripperies must send this disclosure to their counterparties wherever there is a [[title transfer collateral arrangement]]. Where, as in [[stock lending]] and [[derivatives]] trading, there is a ''mutual'' [[title transfer collateral arrangement]] (sometimes ''I'' have to post ''you'' collateral; sometimes ''you'' have to post ''me'' collateral), this leads to the faintly<ref>There goes that British understatement again: I’m learning, after thirty years in these isles.</ref> absurd requirement for the counterparties to send ''each other'' the identical risk notification. WAY TO GO, ESMA. And heavens bless the [[Joint Chiefs of Staff of the Industry Associations]] contrived to make that simple statement — when you transfer legal title to your asset to me, it becomes mine, and you become my creditor for the return of an [[equivalent]] asset — ''fifteen pages long''. | This is mandated by Article {{sftrprov|15}} of [[SFTR]]. Firms engaging in such fripperies must send this disclosure to their counterparties wherever there is a [[title transfer collateral arrangement]]. Where, as in [[stock lending]] and [[derivatives]] trading, there is a ''mutual'' [[title transfer collateral arrangement]] (sometimes ''I'' have to post ''you'' collateral; sometimes ''you'' have to post ''me'' collateral), this leads to the faintly<ref>There goes that British understatement again: I’m learning, after thirty years in these isles.</ref> absurd requirement for the counterparties to send ''each other'' the identical risk notification. WAY TO GO, ESMA. And heavens bless the [[Joint Chiefs of Staff of the Industry Associations]] contrived to make that simple statement — when you transfer legal title to your asset to me, it becomes mine, and you become my creditor for the return of an [[equivalent]] asset — ''fifteen pages long''. | ||