On July 16, ISDA submitted a paper (UPI as the Foundation for OTC Derivatives Reporting: The Case for UPI) to the UK Financial Conduct Authority (FCA). The paper was developed to complement ISDA’s response to the FCA’s discussion paper DP24/2: Improving the UK Transaction Reporting Regime, which is intended to improve transaction reporting under the UK Markets in Financial Instruments Regulation (MIFIR). Specifically, the paper follows a commitment made within the answer to question 10 of the FCA’s discussion paper to conduct further analysis on whether an alternative version of the unique product identifier (UPI) could provide the level of detail and transparency required by the FCA in MIFIR transaction reports.

In the paper, ISDA proposes that the UPI, with only a limited number of minor changes to transaction fields, will successfully fulfil the purpose of an over-the-counter derivatives identifier for MIFIR  transaction reporting, as well as simplify the reporting requirements for market participants.