ROC (Regulatory Oversight Committee)
The Unique Transaction Identifier (UTI)
The UTI is a reference code up to maximum 52 characters to uniquely identify individual OTC derivatives transactions on reports to Trade Repositories (TRs). In particular, a UTI will help to ensure the consistent aggregation of OTC derivatives transactions by minimising the likelihood that the same transaction will be counted more than once.
The key characteristics of UTI codes are:
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Neutrality: The UTI is globally applicable and the generation of the UTI should not reflect jurisdictional differences. While reporting is reflective of jurisdictional variations (e.g. dual sided or single sided reporting), the generation of the UTI should be flexible enough to meet the vast majority of generation needs.
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Uniqueness: Every reportable transaction should have a unique UTI. Different reportable transactions should each have their own UTIs. No UTIs should be reused even if the previous use was on a transaction that is no longer open.
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Consistency: Any individual transaction should have the same UTI even if such transaction is reported more than once to facilitate transactions' matching while contributing to the avoidance of double-counting.
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Persistence: A transaction should keep the same UTI throughout its lifetime. This continuity facilitates the handling of amendments and updates to a report. Some life cycle events affecting existing OTC derivative transactions create one or more new reportable transactions, which such reportable transactions would then each require a new UTI.
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Traceability: If one transaction is replaced by another transaction with a different UTI, then there should be a means of relating the transactions before and after such a change of UTI. Traceability assists in understanding the evolution of transactions and provides an audit trail.
For the full list of characteristics of the UTI, please refer to the UTI Technical Guidance.
The UTI Code is structured as follows:
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Character length: Consist of up to maximum 52 alphanumeric characters.
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Character representations: Upper case alphanumeric characters (A-Z and 0–9 only).
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Characters 1-20: The legal entity identifier of the generating entity, as represented in ISO 17442.
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Characters 21-52: Characters of a unique identifier assigned to the transaction by the generating entity without separators.
The globally harmonised UTI has been published by the International Organisation for Standardisation (ISO) as International Data Standard on 4 August 2020 (ISO 23897:2020 Financial services - Unique transaction identifier (UTI))
Technical Guidance for the UTI
The UTI Technical Guidance was published by CPMI and IOSCO on 28 February 2017 as technical guidance to authorities. The UTI Technical Guidance covers not only the UTI Data Standard (including the UTI's structure and format, its length, which characters should be used in its construction, see section The Unique Transaction Identifier) but also:
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The circumstances in which a UTI should be used, i.e. for reportable transactions that have not previously been allocated a UTI.
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The impact of lifecycle events on the UTI, through setting out principles that provide guidance on when a lifecycle event should or should not cause a new UTI to be used.
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Which entity (or entities) should be responsible for generating UTIs, with the aim of ensuring that there is a well-defined entity responsible for UTI generation for every transaction while respecting the different nature of transactions and providing flexibility.
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When UTIs should be generated, considering the reporting time scales imposed by different jurisdictions.
The ROC, in its capacity of International Governance Body (IGB), is now in charge of a number of responsibilities spelled out in the UTI Governance Arrangements (FSB, December 2017) and now included in the ROC Charter (see also Mandate of the ROC), including updates or changes to the UTI Technical Guidance as necessary. Updated versions of the UTI Technical Guidance may be available among the ROC's publications.