On 9 October 2019, the Financial Stability Board (FSB) published a report setting out governance arrangements for the globally harmonised Unique Product Identifier (UPI) and the unique transaction identifier (UTI). In addition, the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) published a report on governance arrangements for critical over-the-counter (OTC) derivatives data elements other than UPI and UTI (CDE).

These identifiers have been developed to improve transparency, mitigate systemic risk and prevent market abuse. The aggregation of data reported to trade repositories will help to ensure that authorities obtain a comprehensive view of the OTC derivatives market.

Both reports draw out the conclusions, together with implementation plans and next steps to establish an international governance body (IGB) for the UPI, the UTI and the CDE. The reports also conditionally identify the IGB.

The FSB, CPMI and IOSCO identify the Legal Entity Identifier Regulatory Oversight Committee (LEI ROC) as best positioned to be the IGB for the UPI, UTI and CDE, provided that the LEI ROC makes appropriate adjustments to its existing governance to make it fit for purpose. The FSB anticipates that the LEI ROC can adopt and implement these adjustments by mid-2020. In the interim, the FSB’s working group on UTI and UPI governance will take on the IGB governance and implementation functions.

All three bodies recommend that jurisdictions undertake the necessary actions implement the UPI Technical Guidance and governance arrangements by the third quarter of 2022.

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