I am a co-founder of a specialist market data consultancy practice in the U.K. and I am a U.S. citizen by birth. My co-founders and I have been in the market data industry for a combined 100+ years. We have been promoting FIGI over standard identifiers for many years. I believe this is a very important issue and can help the Financial Services industry as a whole by considering the adoption of FIGI. Key Points: 1) The identifier FIGI is more universal and avoids issues where the same security is issued in multiple markets with different currencies. 2) FIGI being an open symbology has now been adopted by the top market data vendors such as Bloomberg, Factset, ICE, S&P, IHS Markit, SIX, Rimes, and others. 3) Third party FinTech vendors who enter into the market have a huge burden to integrate market data feeds into their technology solutions and platforms. FIGI reduces this burden by being a universal identifier which permits newer technologies to come to market faster. An example, a small Swedish Order Management System and IBOR called Limina A.B. was able to enter the market and integrate with all the above market data vendors due to FIGI. This permitted the startup OMS provider to compete at a level playing field with incumbent vendors such as Charles River, Aladdin, Bloomberg AIM, and SS&C EZE. 4) I don't believe it is ethical for an identifier to have a mandatory licensing requirement for all users when the identifier is also required by regulators to be used for reporting purposes. An open symbology is the best approach for a regulated identifier. Thank you for taking these comments into consideration as you review FIGI vs CUSIP, and I am happy to expand on any points if you require additional information. Finally, please see our "about" page to learn more about who Sherpa is and at the bottom of our "about" page you will see our promotion of FIGI. https://www.sherpaconsultancy.net/about-us