ARTICLE
28 August 2015

Input Sought For Development Of A Global Unique Transaction Identifier

AO
A&O Shearman

Contributor

A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
Numerous countries have implemented legislative and regulatory requirements for the reporting of OTC derivatives aimed at improving transparency, mitigating systemic risk and preventing market abuse.
Worldwide Finance and Banking

On August 19, 2015, the Committee on Payments and Market Infrastructures and the International Organization of Securities Commissions launched a consultation aimed at developing guidance for a uniform global unique transaction identifier. The development of a UTI was identified in September 2014 by the Financial Stability Board as one of the critical elements for a mechanism to produce and share global aggregated derivatives reporting data, along with the development a unique product identifier and the harmonization of certain other key data elements. Numerous countries have implemented legislative and regulatory requirements for the reporting of OTC derivatives aimed at improving transparency, mitigating systemic risk and preventing market abuse. To date 26 trade repositories have been established in 16 jurisdictions. The aggregation of data from those trade repositories is key to giving authorities a comprehensive view of the OTC derivatives market and activity and the purpose of the global UTI would be to uniquely identify each OTC derivative transaction required by authorities to be reported to trade repositories. The CPMI and IOSCO are seeking feedback that will assist in developing guidance on a UTI definition, the structure and format of a UTI and responsibility for generating a UTI. Implementation of the final guidance will be the subject of further work by the FSB.

The consultation closes on September 30, 2015. The consultation paper is available at: http://www.bis.org/cpmi/publ/d131.pdf.

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