Trade Associations Detail Objections to the CPMI-IOSCO Plan to Expand Use of Unique Trade Identifiers

A group of trade associations came out against imbedding the Unique Transaction Identifier ("UTI") with, or deriving the UTI from, transactional data that is separately reported, among other objections. The International Swaps and Derivatives Association, Inc., the Institute of International Finance, The Investment Association, and SIFMA (together, the "Associations") were responding to the Committee on Payments and Market Infrastructures' ("CPMI") and IOSCO's consultative report, titled "Harmonisation of the Unique Transaction Identifier." The Associations focused on the fundamental business use of the UTI.

The Associations stated that they are strong proponents of global data harmonization and the efforts to develop guidance for a uniform UTI. But they argued that the primary purpose of the UTI is to uniquely identify a trade across different jurisdictions throughout the trade lifecycle. Therefore, the Associations stated that they do not support imbedding the UTI with, or deriving the UTI from, transactional data that is separately reported. Further, the Associations asserted that the UTI itself should not be used to validate a party to the transaction or contain data to link related transactions. "Any such use is duplicative and would add to the complexity of generating a UTI, increasing the chance for error or unintended interpretations derived from the UTI."