This is the second article of a series devoted to publicly available data produced by the regulatory or supervisory authorities of the financial markets. After a first article dedicated to the LEI (Legal Entity Identifier), it identified the legal entities that trade in the global financial markets. It focuses on benchmark data regarding financial instruments, which are traded on European financial markets. A third article to come will describe liquidity and transparency of instrument calculations.
THE ESMA REFERENTIALS
The European Securities and Markets Authority (ESMA) is better known by the acronym ESMA. The European Union entrusts ESMA to draft the technical standards for the implementation of European directives and regulations. They are the real specifications for the SIs of credit institutions or investment firms.
ESMA is also responsible for centralizing a number of declarations and data from national regulatory authorities in each country of the European Union. Several regulations require ESMA to publish data on its website. We can find for example:
- The list of fund managers covered by the AIFM directive (alternative funds, hedge funds …
- The list of MTFs and Systematic Internalisers, as part of MIFID I
- The list of approved prospectuses, and even the prospectuses themselves, in the framework of the Directive 2003/71 / EC, replaced by Regulation (EU) 2017/1129.
All this data is public and can be consulted at the following address: https://registers.esma.europa.eu/publication/
In this article, we will focus on one of the latest features in this repository family: Financial Instruments Reference Data System, or FIRDS.
Following the MiFID II directive, and more specifically Article 27 of Regulation (EU) No. 600/2014 (MiFIR Regulation). But also following Article 4 of the MAR (Market Abuse Regulation) Directive, ESMA now publishes in the FIRDS references data identifying the instruments traded on European markets.
Unlike European legislation, which is available in all EU languages, ESMA documents are exclusively in English.
Regulatory obligations reminder
Article 26 of MiFIR requires investment firms to execute transactions on financial instruments and to report these transactions to the regulator by D + 1 at the latest. This is the famous transaction reporting, one of the most visible parts of MiFID II, at least in terms of electronic markets and the front office in general.
For these very detailed declarations (65 data fields defined by the ESMA for each transaction) to be useful to the regulator in its mission of market supervision, it is necessary that the latter be able to identify without error and without ambiguity the instrument which is the subject of the transaction.
This is why Article 27 states that “trading venues provide the competent authorities with identifying reference data for the purpose of reporting transactions”. This data must be provided no later than the evening of the first day the instrument is on the side.
This data will be particularly important for OTC transactions. They can relate to instruments that are not listed, not standardized, and therefore potentially difficult to identify for the regulator. In this case, it is the CFI code (Classification of Financial Instruments, ISO 10962) that should be used by the platform operator to describe the instrument.
Reference data details
On the 28th of September 2015, ESMA published its first Regulatory Technical Standards (RTS) for the entire MiFID II Directive, including RTS 23 for baseline data. This RTS 23 has been adopted by the European Commission in the form of the Delegated Regulation (EU) 2017/585.
Table 3 of the Appendix to this Regulation lists the 48 fields to be completed, divided into the following nine categories:
- general fields
- fields concerning the issuer
- fields concerning the trading platform
- fields concerning the notional
- fields relating to bonds or other debt instruments
- fields relating to derivatives and securitized derivative
- commodity derivatives and emission allowances
- interest rate derivatives
- foreign exchange derivatives
The first four categories are common to all types of instruments. For the first five categories, only the one corresponding to the instrument will be present.
The platform on which the title is listed is entered in field 6 by the MIC code (ISO 10383). The repository includes a record for each couple (ISIN, market).
The special case regarding obligations
INVIVOO is the operator of the Electryon platform, which allows trading on corporate bonds. For this type of instrument, we have the following information in FIRDS:
ESMA does not provide certain types of data because its motivation is related to the reporting of transactions. This is the following data:
- Detailed payment schedules for coupons, including the first and last periods, which may be non-standard,
- The rules for calculating periods (30/360, Actual / Actual, etc.),
- The debt rating.
The information listed in the first two points is necessary to correctly calculate an accrued coupon and the yield of the bond. They appear in the prospectus of the issue, that is to say the legal documentation that is produced when the title is created and when it is first put on the market. But flyers are rarely “machine-readable”, they are usually published in PDF format. Moreover, this is an area in which there is very little standardization from one issue to another, which hinders the development of the activity and the liquidity of these markets since the comparison between two securities is all the more difficult.
In point 3, and even though ratings are among the most sought-after information by debt market operators, trading platform operators can not provide this data to ESMA simply because they are not public. Indeed, they are the property of the rating agencies that produce them (S & P, Fitch, Moody’s, …), and their redistribution pays off.
Access to the site, downloading the data
It has been pointed out above that these data of the regulator are public, so let us see concretely how we can get them, and what they look like. All you have to do is point your favorite browser on the ESMA website, where you will find two possible accesses:
ESMA repositories can be queried directly on the site. Immediate answers are obtained on the screen. To do this, click on the following link: https://registers.esma.europa.eu
On the left side of the page, under the heading “Refine Search” are several input fields. In the “Keyword search” field, enter an ISIN code, for example FR0010286294, and type “Enter”.
You get 16 answers (example above) with information such as: Trading place, identified by its MIC code, here XPAR: Euronext Paris
Full name of the instrument (in this case, for a bond, the issuer / rate / maturity is typically classed as BPCE3.75% 24FEB18),
CFI code DBFGFB, see https://en.wikipedia.org/ for a detailed explanation of this codification, and also http://www.iotafinance.com/Decoding-of-codes-CFI-ISO-10962-2015.html for an interactive online decoding tool:
- Issuer of the security, identified by its LEI, here 9695005MSX1OYEMGDF46. The Global LEI Foundation offers an online query tool at https://www.gleif.org/en/lei/search/
- Date of admission to listing …
The other option is to download files from the address: https://registers.esma.europa.eu
The document https://www.esma.europa.eu describes precisely the operating mode and the structure of the files.
Summing up in a very synthetic way:
- ESMA publishes once a week a “full” file, ie containing the reference data for all financial instruments processed in all EU markets, and every day a delta file with changes of the day.
- The files are in zip format, containing unindented XML, with only one line per file (use a tool such as http://xmlwriter.net to obtain a readable version).
- The XML files (see an extract opposite) conform to an XML Schema grammar which is itself provided by ESMA on the same site (for information, these XML schemas come from SWIFT standards and the ISO 20022 standard).
For reasons of very large size, the “full” repository is divided into several files, by type of instrument, identified by the first letter of the CFI code (E for equities, D for Debt, etc.). If the data is still too large, each file will be split in batches of 500,000 records.
Example: as of 27/01/2018, there are 20 files corresponding to about ten types of instruments. For debt securities (letter ‘D’), there are 3 files, since there are more than one million titles listed in the category “debt”.
Exploitation of these files: as the ESMA provides the XSD schemas to which the XML files conform, it is relatively easy to develop programs that extract the data from the XML file to make it easier to manipulate, or in the form of .csv readable by Excel, either in a relational database.
Importance of the referential values
In all IT projects in market finance, there is the question of the securities reference system, ie the exhaustive reference framework for securities and contracts (with details of their characteristics) that the entity is likely to deal with on the markets. Most of the time, every front-, middle- or back-office computing application has its own repository of values. It is rare for these standards to be consistent with each other.
The financial markets themselves provide a daily benchmark, often called the market dictionary: it is the list of financial instruments that can be traded on the market that day. But it is a very limited repository, which contains only characteristics very related to trading on the platform in question: specific coding (other than ISIN), minimum increments of price and quantity, etc.
Alternatively, repositories, with daily updates, can be obtained from leading data providers such as Thomson Reuters, Bloomberg, SIX Telekurs, FactSet, and others, but the cost is often prohibitive.
It is clear that having a unified repository of values is a desirable goal for many reasons, but so far difficult to achieve. However, the regulator, by making available its repository for free, clearly calls into question the established models. We will therefore closely follow the reaction of current suppliers, of course, but also – let us not forget that they are the ones who create the data – the issuers themselves.