On October 16, ISDA responded to the Financial Conduct Authority’s (FCA) consultation CP26/30.  While the consultation is principally focused on cash equity market structure and transparency, ISDA responded to questions on the potential inclusion of equity swaps in the scope of public transparency and the proposed introduction of a three-year window for back-reporting of incorrect and failed post-trade transparency reports.

On the possibility of expanding the scope of transparency to include equity swaps, ISDA expanded on its previous opposition to this in its response to the discussion paper within CP25/20.

On the imposition of a three-year window for back-reporting for post-trade transparency, ISDA argued that the FCA should consult further to determine the appropriate balance between ensuring the market has access to all relevant information about executed transactions and that the regulatory costs for firms are proportionate to the benefits delivered.