The global movement to shorter clearing and settlement cycles is driving
reference data, symbology and unique security identification issues into the
forefront of the financial information industry’s agenda.
The challenges associated with numbering schemes start by recognizing that
financial institutions buy and sell a variety of instruments -- that can be
issued, priced, traded and settled in many ways. As such, different types of
identifiers are relevant at various levels for a variety of functions. The
underlying problem is that the international standard (ISO 6166 ISIN) alone
is not sufficient for the automation requirements of STP. ISIN is a unique
issue identifier, but it is not always a unique security identifier. ISIN
alone is not sufficient for unique identification because one ISIN can be
shared among offerings in multiple locations where each offering may have
slightly different characteristics that nonetheless have significant impact.
This example of Siemens Common Stock (despite the fact that the illustration
is dated) provides a good illustration of the challenge. The issue is listed
on three markets – Frankfurt, Zurich and Paris. The Frankfurt and Zurich
listings are registered in Germany. The Frankfurt listing trades in Euros
and the Zurich listing trades in Swiss Francs. The Paris listing is
registered in France and trades in Euros. The Frankfurt listing can also be
traded on Tradepoint.
|
Issue |
Siemens Ords |
|
ISIN |
DE0007236101 |
|
Register |
DE |
FR |
|
Market |
Deutsche Boerse Frankfurt |
Zurich |
Tradepoint |
Euronext Paris |
|
RIC |
SIEGn.f |
SIEGn.S |
SIEGn.TP |
SIEGP |
|
SEDOL |
5727973 |
5735233 |
5727973 |
5751615 |
|
CCY |
EUR |
CHF |
EUR |
EUR |
ISIN Alone is Not Sufficient
- ISIN is a unique issue identifier, but not always a unique security
identifier.
- ISIN alone is not sufficient because one ISIN can be shared among multiple
offerings in multiple locations.
- ISIN is valid for front-office systems and for aggregation of global
positions.
Official Place of Listing
- The official place of listing (OPOL) identifies primary and secondary
markets where the security is listed. In this example, the OPOL is
Frankfurt, Zurich and Paris.
- OPOL is needed to assist in differentiating the security in the case of
multiple listings. A market issuance in multiple locations will be subject
to different settlement, pricing, tax/corporate event treatment, and
allocation of national numbers.
Register Level Identifier
- Register is the “place” where legal records of security ownership are
held. This security attribute is important for determining transferability
across markets and to help route the security to the correct place of
settlement and holding.
- Register can span different listed securities and different currencies,
can be inferred from OPOL, and must be known at the point of trade execution
to ensure that the risk is manageable.
Event Related Identifiers
- There are attributes associated with financial instruments that are not
“identifiers” but are still critical data elements.
- CSD Bridge Link details are used to determine if a security can be
delivered from one place of settlement to another and must be present at the
time of a trade decision for risk management purposes. CSD Bridge Link
identifier does not exist.
- Place of trade is needed as a practical matter for due diligence and
market compliance (i.e. for trade execution problems, transaction related
taxes, trade related statistics, etc.). Place of trade is also an attribute
of the trade.
The core problem is that there are too many numbers but none that uniquely
identify all attributes required to the necessary level of granularity for
precision. ISIN is needed as the issue level identifier for aggregation of
positions. OPOL and register are indicative data elements that are
attributes of a security, known by issuers and can be collected. CSD bridge
link and place of trade are attributes of a transaction and important. The
fundamental security identification problem is the inability to derive OPOL
(and possibly register) from ISIN.
The industry needs identification numbers to be accurate to facilitate the
objectives of automation and risk management. All instruments that are
traded should have a number and that number should be accurate, timely, well
maintained, precise and available/usable on reasonable terms and conditions
– and satisfy the full lifecycle of a trade, from decision making to
execution, through settlement, reporting, valuation and position keeping.
Current Status of Discussions
This issue has been actively discussed among FISD members, ANNA and
numbering agencies since April 2001. The results of FISD research on the
“requirements for uniqueness” have been evaluated and validated by
practitioners from a diversity of segments within the industry – as well as
by the LSE research associated with extension of SEDOL. Four options for
addressing the issue have received the most attention.
- Market data vendors agree with the definition of the problem and have
addressed it as part of the design of their proprietary symbology. There are
significant commercial and intellectual property challenges that would need
to be addressed to apply a vendor proprietary symbology to address this
issue on an industry-wide basis.
- ANNA agrees with the definition of the problem but maintains that its
members (numbering agencies that are not exchanges) are not in position to
guarantee the collection of OPOL and register level information.
- The ANNA Service Bureau is in position to collect OPOL and link it to
ISIN and is interested in doing so – but has not received authorization from
the ANNA members to provide this additional data product as part of the ISIN
feed.
- The London Stock Exchange agrees with the definition of the issue and has
proposed the extension of SEDOL to address this problem. LSE is moving
forward with its plan to extend SEDOL.
Clarification of SEDOL Proposal
LSE is a member of ANNA and is the national numbering agency for the UK. LSE
has been operating its Security Master File (SMF) service for 30 years and
currently provides information (including global SEDOL codes) on over
400,000 securities traded on UK and international markets.
LSE is running out of numeric SEDOL codes and is moving to alphanumeric
codes to address this problem. This is the primary motivation for the
extension of SEDOL. In addition, LSE understands and agrees with industry
requirements for unique and precise security identification and believes
that it can address this problem by adding data elements/new fields to the
SMF service. Here is an overview of the LSE approach:
|
Current SEDOL Service |
Proposed SEDOL Service |
|
|
|
|
7 Digit Numerical Code |
7 Digit Alphanumeric Code |
|
SEDOL allocation at Place of Listing
Level (OPOL) but not comprehensive |
SEDOL allocation at Place of Listing
Level (OPOL) for listed securities (multiple SEDOL codes for a security
in the case of multiple listings) |
|
Links between SEDOL and ISIN |
Links between SEDOL and ISIN
(multiple SEDOL codes will be linked to a single ISIN in the case of
multiple listings) |
|
New SEDOL codes issued in 3 working
hours |
New SEDOL codes issued in near
real-time via 24/7 web browser |
|
Foreign securities allocated SEDOL
codes on request |
Proactive allocation of SEDOL codes
for all listed securities (listed fixed income and listed equities) |
|
On request assignment of SEDOL codes
for instruments that are not officially listed |
On request assignment of SEDOL codes
for instruments that are not officially listed |
|
Corporate Actions not covered
comprehensively for foreign securities |
Corporate Actions covered
comprehensively |
|
End of Day Feed |
Intraday Feed |
|
No Internet Database Access |
New Internet Browser access to
database |
|
MIC unpopulated (SEDOL codes do not
indicate the place of trade) |
MIC will be populated to identify
where the instrument trades |
|
Proactive maintenance of UK |
Proactive maintenance GLOBALLY |
LSE/SEDOL Terms and Definitions
Agreement on a common vocabulary in discussions associated with unique
security identification is absolutely critical. Semantics and slight
differences in terms and definitions create confusion in the industry and
divert attention away from the objectives of these activities.
We suggest substituting Official Place of Listing (OPOL) for the use of the
terms “market level identifier” and “country level identifier” in these
discussions. “Market level” can mean different things. It can mean
“exchange” or “official exchange” or “country” – depending on the
application.
We further suggest elimination of the concept of “primary market” and
“secondary market.” Most people agree that “primary market” means the first
place of listing in the home country. The term “secondary market” can refer
to a “place of listing” for true multi-listed instruments or for
“exchange/ECN trading privileges.” The critical requirement is to identify
where the precisely defined instrument trades. We suggest the use of the
term “place of trade” to identify where an instrument trades. The place of
trade can be identified using the MIC. The following is our recommendation
of the requirement as applied to the LSE/SEDOL proposal:
- Unique issue identifier = ISIN: Important for security roll-up, risk
management, overall position keeping and trading decisions.
- Unique instrument identifier = Official Place of Listing (OPOL) = SEDOL:
Important for portfolio valuation, fungibility issues for multi-listed
instruments, corporate action issues across OPOLs, risk across OPOLs/currencies,
position keeping, settlement, VMU interaction (cross-bridge settlement, SSI)
and arbitrage across currencies/markets/OPOLs.
- Intra-day trading identification = Place of Trade = SEDOL + MIC = vendor
codes = exchange ticker codes: Important for intra-day pricing decisions,
arbitrage and market compliance.
It is our understanding that many international security master systems use
SEDOL at the Official Place of Listing (OPOL) level. The core complaint has
been that SEDOL does not cover all listed instruments or all places where
the instrument is listed – and therefore has not been a perfect link among
other numbering/symbology schemes.
Changing SEDOL to reflect a numbering scheme at a Place of Trade level would
have significant implications for most master database’s cross-referencing
schemes – and make it very difficult to perform needed functions at the OPOL
level. This would have serious and expensive ramifications for large global
institutions. Extending SEDOL to cover all listed instruments, all places
where the instrument is listed (OPOL) and all places where the instrument
trades (MIC) would appear to solve the requirements for unique instrument
identification with minimal implications to systems.