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FESE welcomes CESR’s decision to adopt two new arrangements facilitating full implementation of transaction reporting mandated by MiFID Article 25.
However, in the course of CESR’s consultation on this issue in January 2007, FESE Members discovered significant problems that would have resulted from the mandatory use of the ISIN code for all derivatives.
The result of this work is the “Alternative Instrument Identifier” (AII), which FESE believes will guarantee the stable uniqueness of the identification of individual instruments for all products covered.