ANNA responded FCA Consultation Paper CP25/32: Improving the UK transaction reporting regime

Brussels, 20th February: The Association of National Numbering Agencies (ANNA) welcomes the opportunity to comment on the FCA Consultation Paper CP25/32: Improving the UK transaction reporting regime (the Consultation).

By way of introduction, ANNA and its member National Numbering Agencies (NNAs) comprising more than 120 key market infrastructures, such as Stock Exchanges, CSDs, Central Banks, Data Vendors and Regulatory Bodies, are active contributors to the development, adoption, promotion and implementation of global financial standards. NNAs allocate International Securities Identification Numbers (ISIN – ISO 6166), Classification of Financial Instruments (CFI – IS0 10962) and Financial Instrument Short Names (FISN – ISO 18774) for more than 200 jurisdictions. Additionally, under the auspices of the International Organization for Standardization (ISO), ANNA is the Registration Authority for the ISIN and the FISN standards and established the Derivatives Service Bureau (DSB) Ltd, an ANNA subsidiary, for the assignment of ISIN, CFI and FISN to OTC derivatives. The DSB is also designated by the Financial Stability Board as the Unique Product Identifier (UPI – ISO 4914) Service Provider for the UPI System, overseen by the Regulatory Oversight Committee.

ANNA supports the global adoption, implementation, and use of ISO standards as they are subject to a proven governance framework to ensure they evolve in line with user requirements, are globally recognised, drive market efficiency, reduce operational risk, and contribute to the development and proper functioning of capital markets. The increased use of these standards improves data quality and provides greater data analysis opportunities for both public authorities and other market participants. These standards are embedded within the international capital markets ecosystem ensuring harmonisation and enabling interoperability amongst market participants.

ANNA recognises the FCA aim to reduce unnecessary duplication in transaction and post-trade reporting, ensuring all requirements are proportionate to their benefit. In addition, there is the need to maintain the ability to gain actionable insights from data needed to support the respective statutory objectives. The goal is to create a streamlined and harmonised framework for transaction reporting across regimes.

The ANNA response to the Consultation focuses on the referenced ISO identification standards (ISO 6166 ISIN, ISO 4914 UPI and ISO 10962 CFI) given the relationship of these standards with ANNA or with the NNAs supporting assignment and maintenance of these standards, in particular the Derivatives Service Bureau (DSB) for OTC derivatives.   A response is provided on relevant questions with specific consideration to referenced ISO standards and the broader Consultation objectives

Read the ANNA comment letter here.

For information about ANNA, its members and activities, please visit anna-web.org 

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