Data Boiler Technologies, LLC
Data Boiler
Data Boiler is a US based company founded in 2013.
ID: 731109791717-49
Lobbying Activity
Response to Applying a unique identifier for public transparency of OTC derivatives
10 Jul 2024
On behalf of Data Boiler Technologies, I am pleased to provide the European Commission (EC) with our comments on the supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council as regards OTC derivatives identifying reference data to be used for the purposes of the transparency requirements laid down in Article 8a(2), and Articles 10 and 21 of that Regulation. Noting AIMA, ISDA and others have chosen option 1 - UPI+, while ESMA wanted option 2 - ISIN in the last round. A workshop was hosted early this year. We at Data Boiler applaud the continuous efforts by the European Commission in narrowing the differences for a practical solution. There are works involved if ISO 6166 ISIN changes on a daily basis. The EC proposal asks for the inclusion of the ISO 4914 UPI code among the ISIN product attributes to enable the aggregation of data across global OTC derivatives markets. It is an attempt to harmonise with non-EU jurisdictions while ensuring the identification of OTC interest rate swaps for the purpose of the MiFIR transparency requirements. Unlike the FCA in UK that have chosen to adopt UPI, it is understandable where the EU wants to be flexible. Using of Boolean flag for non-standard or broken dated terms is an acceptable way to reduce the instance of new OTC ISIN each time. Yet, we are living in the age of real-time instant changes where things dynamically evolve all the times. Why worry about generating a few more bites of data and automating the works, versus the appropriate authentications of all things (e.g., the controversy with CUSIP, long standing issues with loan market identifier, Gleif and others efforts in vLEI, etc). Lets envisage the future development of reference data amid A.I./ machine learning, Public Key Infrastructure (PKI), and other advanced tech innovations. Fragmentation seems inevitable when the UK and EU are taking divergent paths in favour of a friendly competition (e.g., the FCA is prioritising the benefits of immediacy of price publication over full disclosure of traded volume). Consider the give and take as prescribed in this proposal a practical compromise in the short term. There will be need to remain flexible to right-course policy actions in the long term for continuous improvements. Feel free to contact us with any questions and please keep us posted where our expertise might be helpful. Sincerely, Kelvin To Founder and President Data Boiler Technologies, LLC
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