The Lab

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Table of Contents


See also Whisperer Enterprise - Regulatory Fields.


Attachments

Background

Since the collapse of Lehman Brothers in 2010, politicians have wanted to bring the Over The Counter (OTC) derivatives markets under greater control. Their approach to this in the US Congress was to pass a long and complex reform law now referred to as the Dodd Frank Act, named after Chris Dodd and Barney Frank, the two senators who sponsored the bill. Having approved the Dodd Frank Act, the two major regulators, the Securities and Exchanges Commission (SEC) and the Commodities and Futures Trading Commission (CFTC) have transformed the 2300 page law into practical rules to be implemented by banks and financial institutions.

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Product Identification

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Where necessary products are identified with the use of International Securities Identification Numbers (ISINs), as defined by ISO 6166. Refer to https://prod.anna-dsb.com/ for a definitive list of valid ISINs.

For swaps, ISINs are typically maintained at the Leg level. Product-level ISINs are sometimes still supported, but most of the venues have completely moved away from that now, due to the regulatory clarifications provided back in 2017. A Body-Level PackageID should (but usually isn't) be provided to link the two legs together.

Whisperer Enterprise supports both models:

  • Should we receive a top-level ISIN for a swap, we will populate this in the NoBodyRegulatoryFields group with key MiFIDProductISIN.
  • Should we receive the leg-level ISINs for a swap, we will populate these in the NoLegRegulatoryFields group with keyLegMiFIDISIN.
  • Should we receive three ISINs (i.e. both legs and a single top-level one), all will be delivered as above.


Waivers and Flags

Pre-Trade Waivers and Flags are specified to indicate other details relating to the trade:

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