FIA and its members have asked the European Commission to reconsider the mandatory use of International Securities Identification Numbers (ISINs) as the sole option for identification for exchange-traded derivatives. In a letter to Commissioner Jonathan Hill on 5 February, FIA, on behalf of members, said that "it would be more beneficial to both regulators and market participants to maintain the current flexibility in ETD identification and allow continued use of other identifiers (such as the Alternative Instrument Identifier (Aii) as well as ISINs." The letter pointed out that Aii is currently the identifier most commonly used for ETD.
FIA is supportive of the policy objectives of MiFID II/MiFIR and agrees that, once implemented, the combined Level 1 and Level 2 requirements of will further enhance market transparency for the overall benefit of investors and end-users in European capital markets. Transacttion reporting will enable closer and enahcned supervision of markets by regulators. However, FIA members also feel strongly that the application of a 'one-size-fits-all' approach across all asset class transaction types is not feasible not fit for purpose.