Joint Trade Association Response on Unique Product Identifiers

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.

ISDA Omnibus Canadian Representation Letter

On September 2, 2026, ISDA published the Omnibus Canadian Representation Letter (the “Omnibus Canadian Letter”), which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The...

Response to SEC on FICC Guaranty Fund

On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...