On January 9, ISDA, the Alternative Investment Management Association and the European Banking Federation submitted a joint response to a European Commission (EC) consultation on the best way to identify over-the-counter (OTC) derivatives for the purpose of transparency requirements under the Markets in Financial Instruments Regulation (MIFIR).
In the response, the associations highlight their preference for unique product identifiers (UPIs) (ISO4914) in MIFIR regulatory technical standard (RTS) 2, augmented by several other fields to ensure optimal granularity. RTS 2 sets out the technical detail of transparency requirements in MIFIR. The associations further stated that the most efficient way for users of transparency and consolidated tape data to understand the tenor of instruments covered by these requirements would be for market participants to report the effective date (among the additional fields needed). Along with the time stamp of the trade, this would allow approved publication arrangements to calculate the tenor for these users. Furthermore, the associations suggest the EC conduct a cost/benefit analysis on the use of UPI as the basis for MIFIR transaction reporting requirements.
Currently, MIFIR requires ISINs as the basis for transparency and transaction reporting requirements, but this approach has been sub-optimal in some asset classes – notably, interest rate derivatives.
Documents (1) for Joint Trade Association Response on Unique Product Identifiers
Latest
Four Reforms for Successful US Treasury Clearing
The US Treasury market is the world’s biggest and most systemically important market. It’s the oil that keeps the wheels of the global financial system turning and is the primary means by which the US government raises funding. It’s therefore...
ISDA Response to ESMA on CCP Model Validation
On April 7, ISDA responded to the European Securities and Markets Authority’s (ESMA) consultation on draft regulatory technical standards (RTS) under article 49(5) of the European Market Infrastructure Regulation (EMIR), on the conditions for an application for validation of model...
Scott O'Malia Testimony on US Treasury Clearing
On April 8, ISDA CEO Scott O'Malia testified on the implementation of mandatory US Treasury clearing before the US House of Representatives Committee on Financial Services Task Force on Monetary Policy, Treasury Market Resilience, and Economic Prosperity. “The US Treasury...
Joint Letter on Changes to French General Tax Code
On March 31, ISDA, the Association for Financial Markets in Europe (AFME) and the International Securities Lending Association (ISLA) sent a letter to the French tax authority about changes being made to Articles 119 bis A and 119 bis 2...