On November 9, ISDA sent a paper to the European Commission and UK Financial Conduct Authority recommending that over-the-counter (OTC) derivatives are identified using unique product identifiers (UPIs) for EU and UK transparency requirements, augmented with some key trade-level attributes (known as UPI+). ISDA believes this would be more appropriate than ISINs because it would enable users to aggregate and perform meaningful analysis on instrument pricing across the market. These additional attributes would ensure OTC derivatives could be identified and aggregated in a way that is useful to market participants while providing sufficient granularity to distinguish between different products.