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.

Response to EC Consultation on Carbon Price

On June 10, ISDA responded to the European Commission’s (EC) consultation on the calculation of the carbon price paid in a third country under Article 9 of the Carbon Border Adjustment Mechanism (CBAM). ISDA supports the EC’s proposal that evidence...

Response to CFTC on Clearing Requirements

On June 11, ISDA responded to the US Commodity Futures Trading Commission’s notice of proposed rulemaking on the clearing requirement determination under Section 2(h) of the Commodity Exchange Act for interest rate swaps to account for Canadian dollar-denominated and Mexican...

Digital Assets and Derivatives: Where Next?

Digital assets are moving into a phase of institutional integration into derivatives markets. Trading venues, custodial infrastructures and tokenization platforms now exist across both traditional financial markets and public blockchain networks. While this diversity has accelerated innovation and liquidity formation,...