The Structured Products Association (SPA) has posted its comments about the Retail Structured Products (RSP) draft principles document that circulated last month. The RSP principles were drafted by five associations, namely, the International Swaps and Derivatives Association (Isda), the European Securitisation Forum, the International Capital Market Association, the London Investment Banking Association and the Securities Industry and Financial Markets Association.
Impressively, the SPA comments are as long as the original principles. The draft was designed by the five associations to focus on how "structured products combine various components (which) may in practice result in different parties being responsible for different aspects of the related regulatory obligations." The principles therefore "focus on how to address this issue, given that all parties have a common interest in customers obtaining satisfaction with regards to their legitimate expectations as to performance of the investment."
The SPA says it broadly agrees with the RSP draft but maintains that “in order to be comprehensive, the RSP principles should acknowledge the differences in market dynamics and regulation in various markets.”
The comments make for interesting reading and can be accessed here.
If you have any thoughts of the SPA comments, or indeed the RSP draft, do let me know…