Common Data Template for Global Systemically Important Banks

GFMA*, the American Bankers Association (ABA), The Clearing House, and the Financial Services Roundtable provide comments to the Financial Stability Board on the Consultative Document: Understanding Financial Linkages: A Common Data Template for Global Systemically Important Banks published on October 6, 2011.  The groups feel that an important step prior to the adoption of a common data template would be the creation of standardized definitions of the data elements requested in current and pending international and national regulatory reporting initiatives. The groups outline this and other concerns with the specific aspects of this proposal and offer recommendations for moving forward.

*GFMA joins together the common interests of hundreds of financial institutions across the globe. SIFMA is the independent U.S. regional member of the Global Financial Markets Association (GFMA). The Association for Financial Markets in Europe (AFME) and the Asian Securities and Financial Markets Association (ASIFMA) represent the independent European and Asian regional members of GFMA.