FESE understands the mandate of the Harmonisation Group to develop guidance regarding the definition, format and usage of key OTC derivatives elements. However, we consider that this work should be reviewed in the context of the broader policy discussions on the instrument identifiers taking place in key jurisdictions. We would like to highlight our concerns with proposals by European policy makers on product identifiers under the proposed mandatory use of the International Securities Identification Number (ISIN) for exchange traded derivatives in MiFID II / MiFIR.

Read the full position here :