Have agencies sufficiently defined the term “core clearing & settlement organizations” – so that all organizations can identify themselves?
The definition is, for the most part, clear. However, UBS PaineWebber requests further clarity between “core clearing & settlement organizations” and “significant players.” 3. Have agencies provided sufficient guidance for firms to determine whether they play “significant roles” in critical financial markets? UBS PaineWebber understands the importance of identifying significant roles within each of the defined markets. However, UBS PaineWebber does not feel that the Agencies have provided sufficient guidance for firms to make that determination on their own. Guidelines that take into account factors such as dollar amount, volume requirements or market share percentage on a rolling average could assist a firm to determine whether it plays a “significant role” within a particular market. Furthermore, UBS PaineWebber believes that the Agencies should provide some form of confirmation of these determinations. . 4. Are there other measures/facts/circumstances that should be used to determin
