September 28, 2020
Thank you for you looking at these reporting requirements as well as other aspects of filing 13-F statements.
I've had first hand experience in having to build these
statements on behalf of asset managers as a CTO and senior technologist for several buy side firms.
Adoption of XML format is a significant improvement.
One thing i'd like to add is you have added a question in II, D. 25 about accepting FIGI's as alternative to CUSIP.
I ask that you seriously consider adopting this as well as adopting FIGI as a universal alternative to CUSIP.
I've had countless tasks put before me in my long career that revolve around joining instruments/positions with their security identifiers.
These have included both for data modelling internally and reporting externally as have had my colleagues.
In my line its called maintaining a "security master", an non trivial exercise.
Prior to FIGI and Bloomberg's initiative to make them a universal identifier,
an open and accessible solution to lookup, match and translate between other MIC's including CUSIP an solution did not exist.
Freely available to all operations, developers, service providers and stakeholders in this process we know have that solution.
By adopting FIGI's the actual implementers -- be they technical or non-technical -- of these reports have
both an easy to use website and a scalable webservice to search and match holdings and ensure accurate reporting.
FIGI's universe exceeds CUSIP and as such you can ensure that a FIGI is accurately matched to the correct non-fungible instrument.
I would urge anyone looking at this to seriously consider making FIGI's a recognized alternative.
Thank you.