On March 11, ISDA submitted a paper to the European Securities and Markets Authority (ESMA) setting out its view on how the delegated act specifying the identifying reference data to be used for over-the-counter (OTC) derivatives transparency under the Markets in Financial Instruments Regulation (MIFIR) should be implemented.
The delegated act leaves room for interpretation by ESMA on which unique identifier should be used, creating a risk that the International Securities Identification Number may be retained in some form. The ISDA paper makes the case for the use of the unique product identifier (UPI), maintaining its position that this will create more effective transparency and a more attractive consolidated tape, as well as reducing cost and complexity, and aligning with the increasing international consensus on using the UPI as the basis for OTC derivatives identification.
The paper can be found below.
Documents (1) for ISDA submits paper to ESMA on OTC derivatives identifier for MIFIR transparency
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