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Osttra Group

Osttra

We bring together four businesses that have been at the heart of post-trade evolution and innovation for more than 25 years: MarkitServ, Traiana, TriOptima Reset.

Lobbying Activity

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

2 Oct 2025 · Markets in Financial Instruments Directive (MiFID II) and Regulation (MiFIR)

Response to Applying a unique identifier for public transparency of OTC derivatives

10 Jul 2024

We welcome the DA as an important step towards greater efficiency and clarity in post-trade transparency for OTC derivatives under MiFIR. Our services extend from post-trade processing, confirmation, trade affirmation, portfolio reconciliation, cashflow affirmation, collateral management, risk calculations (PV, Initial Margin, XVA), through to multilateral compression, benchmark conversion, and counterparty risk and IM optimisation. We help clients to meet a broad range of regulatory challenges, allowing them to optimise resources by lowering costs, optimising operational, regulatory and credit risk, improving counterparty exposure management, and reducing systemic risk in their derivatives portfolios. Today OSTTRA, through our MarkitWire and TradeServ services, offer post-trade processing and legal confirmation services to the OTC derivatives market globally. This means we are at the heart of post trade processing in the two asset classes being considered in this Consultation and are well versed in the efficiencies available and the challenges faced by firms when adopting new standards for post trade processing. As the leading end-to-end post-trade solutions provider, OSTTRA is pleased to provide its comments to the EC Draft Delegated Act on OTC Derivatives Identifying Reference Data for the purpose of transparency requirements (the DA). We strongly believe that the Unique Product Identifier (ISO 4914), a globally agreed unique product identifier, augmented by a small number of additional transaction related fields (a.k.a. UPI+), is the optimal means of identifying OTC derivatives for transparency purposes, striking the appropriate informed balance between granularity and flexibility. The current design of the OTC ISIN (that are erroneously based on securities which are highly standardised instruments with no customisation, unlike OTC derivatives) significantly damages the transparency goals of the EU and adds cost and inefficiency to the EU markets. However, we recognise that ESMA have a preference to maintain a reformed OTC ISIN, due to their systems requiring significant change to switch from an overly granular OTC identifier, implying significant associated one-time costs and a significant period of time to deliver the required changes. We appreciate and support the ECs preference for an outcome that solves the OTC ISIN proliferation issue and creates identifiers which are useful for transparency purposes. We also appreciate that the EC has reflected at length on the approach that should be pursued to limit OTC ISIN proliferation while also ensuring data integrity. We support the ECs preference that the tenor of in-scope OTC derivatives should be derived from transaction reports and trade reports as transaction specific details rather than being part of the identifier. We also welcome the inclusion of the UPI in the fields included in the draft Delegated Act however, we would note that the UPI should also be included in RTS 2 (transparency reporting), 22 (transaction reporting) and 23 (reference data) requirements to enable an eventual transition to UPI. We note that the recent ESMA consultation on RTS 23 did not propose its inclusion. In addition, we also ask that the EC initiate consultations further to its empowerment under Article 27.5, 2nd paragraph to specify identifying reference data to be used with regard to OTC derivatives for the purposes of Article 26 (transaction reporting) as soon as possible. While we are supportive of the co-existence of UPI alongside OTC ISIN for a time-limited period to facilitate an orderly transition to UPI, we underline the importance of limiting OTC ISIN proliferation across all asset classes during that period (e.g., equity derivatives, and FX derivatives, which both suffer the same material OTC ISIN proliferation issue) Our detailed feedback is provided in the attached letter. Kind Regards
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and BNP PARIBAS and International Swaps and Derivatives Association

22 Sept 2023 · MIFIR OTC derivatives identifiers, EU capital markets and their regulatory framework