The UPI has Gone Live for Regulatory Reporting (CFTC)

One key part of the regulatory reporting changes which are being rolled out globally in 2024, involves the introduction of the Unique Product Identifier (UPI) into the requirements.

The CFTC took the lead as the first G20 jurisdiction to commence Unique Product Identifier (UPI) reporting in their CFTC Rewrite Phase 2, starting earlier this week, on 29 January 2024. This is another significant stride towards fulfilling the G20 commitments aimed at improving the regulators’ understanding of global systemic risk.

List of products affected

The Commodity Futures Trading Commission (CFTC) has incorporated the UPI for Credit, Equity, Foreign Exchange (FX) and Interest Rates asset classes in OTC derivatives reporting requirements. However, it is important to note that the reporting scope for CFTC does not encompass the Commodity asset class within the CFTC framework.   

Accuracy of UPI

When retrieving a UPI from ANNA-DSB, it is important to verify that all product attributes of the UPI chosen align with the product being reported. If an exact match is not available, a new UPI should be generated.

ANNA-DSB has completed the Pre-Population process on their UPI Production environment which means there are now approximately 600,000 new UPIs in the database. Pre-Population is a process which attempts to assign a UPI code to each existing OTC ISIN record and will be applied to both active and expired OTC ISINs.

When a user attempts to create a UPI with attributes of an existing product on ANNA-DSB database, the system will retrieve an existing UPI for the user. This prevents duplication in UPI creation on the database.

Free User type

Although ANNA-DSB offers free access, there are certain limitations. Users cannot generate new Unique Product Identifiers (UPIs) or retrieve recently created UPIs before the End of Day T+1. This constraint poses a challenge for reporting firms aiming to meet the T+1 reporting deadline with a valid UPI. However, for users seeking to reference existing products in the database, this free access can still be beneficial.

In order to ensure accurate UPI reporting, reporting firms will need to map all their current product attributes to source a UPI from ANNA-DSB. This transition requires extra effort and potential system upgrades to trading, confirmation platforms, or reporting solutions. TRAction as a delegate party to your trade reporting, will efficiently extract and source all required UPIs for every product you trade.

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