May 24, 2018

Financial Stability Board
[email protected]

Re: Governance Arrangements for the Unique Product Identifier (UPI), Second Consultation Document

The Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG” or “AMG”)1 appreciates the opportunity to provide the Financial Stability Board (“FSB”) comments on the second consultation document regarding governance arrangements for the Unique Product Identifier (“UPI”)2.

As we have noted in our previous comments regarding the FSB’s work on UPI, SIFMA AMG appreciates the FSB’s coordination on international level to develop guidance for trade reporting, and strongly supports the establishment of global standards for data, and the regulatory goal of utilizing a globally-harmonised product identifier for derivatives. SIFMA AMG particularly appreciates the efforts to work across jurisdictions to ensure a consistent approach resulting in one solution to address regulators’ need to have certain data aggregated into a single field.

We continue to urge regulators to take into consideration the work that has already been done to identify derivatives instruments under MiFID II. Ideally the derivatives markets and related regulatory oversight would benefit from a single framework to cover product identifiers and usages in all jurisdictions. A framework of a single identifier would be most beneficial for both the industry and regulatory oversight, as it would improve consistency and data quality, reduce the potential for errors and unnecessary cost and complexity in reporting technology, systems, connections and communication flow.

While we support a globally harmonized product identifier for derivatives, we believe that further explanation is required to understand the global framework for product identifiers, particularly the hierarchy between the ISIN and UPI, and the specific regulatory uses for both that could not be achieved with either identifier.

We have provided below our specific responses to the questions asked in the second consultation document regarding governance arrangements for the UPI.

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1 SIFMA AMG’s members represent U.S. asset management firms whose combined global assets under management exceed $34 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.

2 Governance arrangements for the unique product identifier (UPI), Second consultation document