Joint Rule Establishing Data Standards under the Financial Data Transparency Act of 2022
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FDIC Financial Institution Letters › Joint Rule Establishing Data Standards under the Financial Data Transparency Act of 2022
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
coaching organization, and has the
ability to support the candidate
consistent with the goals of the SESCDP.
The coach and the candidate are jointly
responsible for a productive coaching
relationship and are required to meet for
a minimum of 10 hours during the
course of the SESCDP.
*
*
*
*
*
■4. Add § 412.303 to read as follows:
§ 412.303
Senior Executive Service
candidate development program (SESCDP)
oversight and evaluation.
(a) An agency must complete and
maintain program evaluations pursuant
to training evaluation requirements in 5
CFR 410.202 and must use OPM-
developed evaluation templates for
completion, respectively, by individual
SESCDP participants and agency
program managers:
(1) Upon completion of each
individual SESCDP cohort;
(2) Annually for the overarching
SESCDP; and
(3) To collect evaluation data for the
purpose of identifying and
implementing program enhancements or
alternative approaches to program
administration.
(b) To seek OPM re-approval of an
SESCDP policy, an agency must submit
its current program policy and
completed overarching program
evaluation template. Evaluations must
include initial SES placement rates for
graduates who receive a QRB
certification and demonstrate that the
agency maintains a minimum placement
rate as specified by OPM policy and
guidance. Individual participant
program cohort evaluation templates are
not required for re-approval; however,
OPM reserves the right to request
templates for each individual cohort
during the current approval period.
[FR Doc. 2026–12811 Filed 6–24–26; 8:45 am]
BILLING CODE 6325–39–P
DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
12 CFR Part 15
[Docket ID OCC–2024–0012]
RIN 1557–AF22
FEDERAL RESERVE SYSTEM
12 CFR Part 262
[Docket No
not required for re-approval; however,
OPM reserves the right to request
templates for each individual cohort
during the current approval period.
[FR Doc. 2026–12811 Filed 6–24–26; 8:45 am]
BILLING CODE 6325–39–P
DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
12 CFR Part 15
[Docket ID OCC–2024–0012]
RIN 1557–AF22
FEDERAL RESERVE SYSTEM
12 CFR Part 262
[Docket No. R–1837]
RIN 7100 AG–79
FEDERAL DEPOSIT INSURANCE
CORPORATION
12 CFR Part 304
RIN 3064–AF96
NATIONAL CREDIT UNION
ADMINISTRATION
12 CFR Part 753
RIN 3133–AF70
CONSUMER FINANCIAL PROTECTION
BUREAU
12 CFR Part 1077
[Docket No. CFPB–2024–0034]
RIN 3170–AB20
FEDERAL HOUSING FINANCE
AGENCY
12 CFR Part 1226
RIN 2590–AB38
COMMODITY FUTURES TRADING
COMMISION
17 CFR Part 140
RIN 3038–AF43
SECURITIES AND EXCHANGE
COMMISSION
17 CFR Part 256
[Release No. 33–11420; 34–105536; IA–
6967; IC–36163; File No. S7–2024–05]
RIN 3235–AN32
DEPARTMENT OF THE TREASURY
31 CFR Part 151
[Docket No. TREAS–DO–2024–0008]
RIN 1505–AC86
Financial Data Transparency Act Joint
Data Standards
AGENCY: Office of the Comptroller of the
Currency (OCC), Treasury; Board of
Governors of the Federal Reserve
System (Board); Federal Deposit
Insurance Corporation (FDIC); National
Credit Union Administration (NCUA);
Consumer Financial Protection Bureau
(CFPB); Federal Housing Finance
Agency (FHFA); Commodity Futures
Trading Commission (CFTC); Securities
and Exchange Commission (SEC);
Department of the Treasury (Treasury).
ACTION: Final rule.
SUMMARY: The OCC, Board, FDIC,
NCUA, CFPB, FHFA, CFTC, SEC, and
Treasury are publishing a final joint rule
to establish data standards to promote
interoperability of financial regulatory
data across these agencies
ousing Finance
Agency (FHFA); Commodity Futures
Trading Commission (CFTC); Securities
and Exchange Commission (SEC);
Department of the Treasury (Treasury).
ACTION: Final rule.
SUMMARY: The OCC, Board, FDIC,
NCUA, CFPB, FHFA, CFTC, SEC, and
Treasury are publishing a final joint rule
to establish data standards to promote
interoperability of financial regulatory
data across these agencies. The
standards established pursuant to this
joint rule will later be considered for
potential incorporation (to the extent
feasible) into data standards to be
adopted for certain collections of
information in separate rulemakings by
the agencies or through other actions
taken by the agencies. At the effective
date, the joint rule will not change any
reporting requirements without further
action by the agencies. The agencies are
publishing this joint rule as required by
the Financial Data Transparency Act of
2022.
DATES: Effective date: The joint rule is
effective on October 1, 2026. At the
effective date, the joint rule will not
change any reporting requirements
without further action by the agencies.
FOR FURTHER INFORMATION CONTACT:
OCC: Richard Heeman, Enterprise
Data Governance Program Manager,
Office of the Chief Information Officer
and Chief Data Officer, (202) 945–7224;
Allison Hester-Haddad, Special
Counsel, John Cooper, Counsel, Chief
Counsel’s Office, (202) 649–5490; 400
7th Street SW, Washington, DC 20219.
If you are deaf, hard of hearing, or have
a speech disability, please dial 711 to
access telecommunications relay
services
Enterprise
Data Governance Program Manager,
Office of the Chief Information Officer
and Chief Data Officer, (202) 945–7224;
Allison Hester-Haddad, Special
Counsel, John Cooper, Counsel, Chief
Counsel’s Office, (202) 649–5490; 400
7th Street SW, Washington, DC 20219.
If you are deaf, hard of hearing, or have
a speech disability, please dial 711 to
access telecommunications relay
services.
Board: Katherine Tom, Chief Data
Officer, (202) 872–4986; Nuha
Elmaghrabi, Clearance Officer, (202)
471–0928, Office of the Chief Data
Officer; William Treacy, Adviser, (202)
452–3859, Division of Supervision and
Regulation; Asad Kudiya, Associate
General Counsel, (202) 475–6358;
Gillian Burgess, Senior Counsel, (202)
489–2422; Sumeet Shroff, Senior
Counsel, (202) 568–2560, Legal
Division, Board of Governors of the
Federal Reserve System, 20th Street and
Constitution Avenue NW, Washington,
DC 20551. For users of TTY—TRS,
please call 711 from any telephone,
anywhere in the United States.
FDIC: Geoffrey Nieboer, Chief Data
Officer, (703) 516–5850,
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
1 Public Law 117–263, title LVIII, 136 Stat. 2395,
3421 (2022) (adding, among other things, a new
section 124 of the Financial Stability Act of 2010,
which is codified at 12 U.S.C. 5334).
2 The term ‘‘covered agencies’’ is defined under
the FDTA to include ‘‘any . . . primary financial
regulatory agency designated by the [Secretary of
the Treasury].’’ On May 3, 2024, the Secretary of the
Treasury designated the CFTC as a covered agency
under the FDTA. See FDTA section 5811(a).
3 Financial Data Transparency Act Joint Data
Standards, 89 FR 67890 (Aug. 22, 2024) (Notice of
Proposed Rulemaking).
ChiefDataOfficer@fdic.gov; Federal
Deposit Insurance Corporation, 550 17th
Street NW, Washington, DC 20429
d by the [Secretary of
the Treasury].’’ On May 3, 2024, the Secretary of the
Treasury designated the CFTC as a covered agency
under the FDTA. See FDTA section 5811(a).
3 Financial Data Transparency Act Joint Data
Standards, 89 FR 67890 (Aug. 22, 2024) (Notice of
Proposed Rulemaking).
ChiefDataOfficer@fdic.gov; Federal
Deposit Insurance Corporation, 550 17th
Street NW, Washington, DC 20429.
NCUA: Office of Business Innovation:
Amber Gravius, Chief Data Officer, (703)
548–2411, agravius@ncua.gov, and
Aaron Langley, Business Innovation
Officer, (703) 548–2710, alangley@
ncua.gov; Office of General Counsel:
Gira Bose, Senior Attorney, (703) 518–
6562, gbose@ncua.gov, and Ariel
Pereira, Senior Attorney, (703) 548–
2778, apereira@ncua.gov.
CFPB: Dave Gettler, Paralegal
Specialist, Office of Regulations, at (202)
435–7700 or https://reginquiries.
consumerfinance.gov/. If you require
this document in an alternative
electronic format, please contact CFPB_
Accessibility@cfpb.gov.
FHFA: Matthew Greene, Office of the
Chief Data Officer, (202) 649–3174,
Matthew.Greene@fhfa.gov; or Angela
Supervielle, Office of General Counsel,
(202) 649–3973, angela.supervielle@
fhfa.gov. These are not toll-free
numbers. For TTY/TRS users with
hearing and speech disabilities, dial 711
and ask to be connected to any of the
contact numbers above.
CFTC: Tom Guerin, Senior Special
Counsel, (202) 743–4194, tguerin@
cftc.gov, Division of Data; Stephen
Andrews, Deputy General Counsel for
Regulation, (202) 418–5611,
sdandrews@cftc.gov, Office of the
General Counsel; in each case at the
Commodity Futures Trading
Commission, Three Lafayette Centre,
1151 21st Street NW, Washington, DC
20581.
SEC: Greg Scopino and Mark Stewart,
Senior Counsels; Bradley Gude, Branch
Chief; or Brian McLaughlin Johnson,
Assistant Director, Investment Company
Regulation Office, Division of
Investment Management, at (202) 551–
6792; or Parth Venkat, Office of the
Chief Data Officer, at (202) 551–3430,
U.S
ures Trading
Commission, Three Lafayette Centre,
1151 21st Street NW, Washington, DC
20581.
SEC: Greg Scopino and Mark Stewart,
Senior Counsels; Bradley Gude, Branch
Chief; or Brian McLaughlin Johnson,
Assistant Director, Investment Company
Regulation Office, Division of
Investment Management, at (202) 551–
6792; or Parth Venkat, Office of the
Chief Data Officer, at (202) 551–3430,
U.S. Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–8549.
Treasury: Eric Froman, Assistant
General Counsel, eric.froman@
treasury.gov, (202) 622–1942,
Department of the Treasury, 1500
Pennsylvania Avenue NW, Washington,
DC 20220.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction and Background
A. Financial Data Transparency Act
Statutory Requirements
1. Joint Agency Rulemaking
2. Agency-Specific Rulemakings
3. Consultations
B. Joint Agency Establishment vs.
Individual Agency Adoption
C. Summary of the Proposed Joint Rule
D. Brief Summary of Comments Received
on the Proposed Joint Rule
1. Administrative Law Comments
2. Municipal Securities Market Comments
II. Final Joint Rule
A. Collections of Information
B. Legal Entity Identifier
C. Other Common Identifiers
1. Unique Product Identifier (UPI) and
Classification of Financial Instruments
(CFI)
2. Financial Instrument Global Identifier
(FIGI) and Other Financial Instruments
Identifiers
3. Dates
4. States, Possessions, or Military ‘‘States’’
of the United States of America or
Geographic Directionals
5. Countries and Their Subdivisions
6. Currencies
D. Data Transmission and Schema and
Taxonomy Format Standards
E. Accounting and Reporting Taxonomies
and Census Tracts
III. Effective Date
IV. Other Matters
A. Regulatory Planning and Review
B. Paperwork Reduction Act
C. Regulatory Flexibility Act
D. Plain Language
E. Riegle Community Development and
Regulatory Improvement Act of 1994
F. Unfunded Mandates Reform Act of 1995
Determination
G. Executive Order 13132—Federalism
H
my Format Standards
E. Accounting and Reporting Taxonomies
and Census Tracts
III. Effective Date
IV. Other Matters
A. Regulatory Planning and Review
B. Paperwork Reduction Act
C. Regulatory Flexibility Act
D. Plain Language
E. Riegle Community Development and
Regulatory Improvement Act of 1994
F. Unfunded Mandates Reform Act of 1995
Determination
G. Executive Order 13132—Federalism
H. Assessment of Federal Regulations and
Policies on Families
I. Congressional Review Act
I. Introduction and Background
On December 23, 2022, the Financial
Data Transparency Act of 2022 (FDTA)
was signed into law.1 The FDTA seeks
to promote interoperability of financial
regulatory data. The FDTA directs the
OCC, Board, FDIC, NCUA, CFPB, FHFA,
CFTC,2 SEC, and Treasury (each
referred to individually as an Agency
and collectively as Agencies) to jointly
establish data standards through
rulemaking (final joint rule). The FDTA
also directs the OCC, Board, FDIC,
NCUA, CFPB, FHFA, and SEC (each
referred to individually as an
implementing Agency and collectively,
as implementing Agencies) to issue
individual rules adopting applicable
joint standards for certain collections of
information under their respective
purview (Agency-specific rulemakings).
In August 2024, the Agencies issued
a Notice of Proposed Rulemaking
inviting comment on a proposed joint
rule to establish data standards pursuant
to the FDTA (proposed joint rule).3 As
described in detail below, the Agencies
are now finalizing the joint rule, with
certain changes based on public
comments on the proposed joint rule.
The Agencies are establishing the joint
standards as shown in Table 1
, the Agencies issued
a Notice of Proposed Rulemaking
inviting comment on a proposed joint
rule to establish data standards pursuant
to the FDTA (proposed joint rule).3 As
described in detail below, the Agencies
are now finalizing the joint rule, with
certain changes based on public
comments on the proposed joint rule.
The Agencies are establishing the joint
standards as shown in Table 1. These
standards are established as proposed,
except that the Agencies are (1) not
establishing the proposed joint standard
of the Financial Instrument Global
Identifier (FIGI) for the identification of
financial instruments, (2) specifying that
International Organization for
Standardization (ISO) 10962—Securities
and related financial instruments—
Classification of financial instruments
(CFI) is to be used in the classification,
rather than identification, of financial
instruments that are not swaps or
security-based swaps, (3) establishing
ISO 8601 for dates without reference to
the Basic format option, and (4) more
explicitly stating that the Agencies may
tailor the data standards they ultimately
adopt or adopt data standards not
established in the final joint rule.
TABLE 1—JOINT STANDARDS AS ESTABLISHED IN FINAL JOINT RULE
Subject matter
Standard
Legal entity ......................................
ISO 17442—Legal Entity Identifier (LEI).
Swaps and securities-based swaps
ISO 4914—Financial Services—Unique product identifier (UPI).
Classification of financial instru-
ments other than swaps and se-
curities-based swaps.
ISO 10962—Securities and related financial instruments—(CFI).
Dates ...............................................
ISO 8601—Date and time—Representations for information interchange.
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instru-
ments other than swaps and se-
curities-based swaps.
ISO 10962—Securities and related financial instruments—(CFI).
Dates ...............................................
ISO 8601—Date and time—Representations for information interchange.
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
4 The Financial Stability Act, codified at 12
U.S.C. 5321 et seq., is title I of the Dodd-Frank Wall
Street Reform and Consumer Protection Act.
5 Codified at 12 U.S.C. 5334.
6 The scope of ‘‘financial entities under the
jurisdiction of the Agency’’ will be addressed by
each Agency in its Agency-specific rulemaking or
other action. The Commodity Exchange Act (CEA)
and CFTC regulations currently provide a definition
of ‘‘financial entity’’ in CEA section 2(h)(7)(C),
CFTC regulation 1.3 and CFTC regulation 45.1 for
certain specified purposes. In each instance, the
current definition of ‘‘financial entity’’ is the
definition set forth in CEA section 2(h)(7)(C). The
CFTC does not believe that Congress intended for
the CEA definition of ‘‘financial entity’’ to be used
for the purpose of the joint data standards required
by the FDTA. The CFTC expects to either adopt a
definition of ‘‘financial entity’’ for the purpose of
the FDTA and/or to address the meaning of the term
as it considers CFTC collections of information.
7 Section 124(a)(3) of the Financial Stability Act.
8 The term ‘‘machine-readable’’ is defined as data
in a format that can be easily processed by a
computer without human intervention while
ensuring no semantic meaning is lost. 44 U.S.C.
3502(18)
n of ‘‘financial entity’’ for the purpose of
the FDTA and/or to address the meaning of the term
as it considers CFTC collections of information.
7 Section 124(a)(3) of the Financial Stability Act.
8 The term ‘‘machine-readable’’ is defined as data
in a format that can be easily processed by a
computer without human intervention while
ensuring no semantic meaning is lost. 44 U.S.C.
3502(18).
9 The term ‘‘metadata’’ is defined as structural or
descriptive information about data such as content,
format, source, rights, accuracy, provenance,
frequency, periodicity, granularity, publisher or
responsible party, contact information, method of
collection, and other descriptions. 44 U.S.C.
3502(19).
10 Within the field of data science, the terms
‘‘schema,’’ ‘‘taxonomy,’’ and ‘‘ontology’’ model are
used in various and sometimes conflicting ways.
For example, sometimes the term schema refers
only to the description of the syntax of a data asset,
while other times, the term can refer to a
description of the syntax, semantic meaning, and
organizational structure. Similarly, sometimes the
term taxonomy refers only to the description of the
semantic meaning of a data asset, while other times,
the term can refer to a description that includes
syntax, semantic meaning, and hierarchical
structure. The term ontology model may refer to the
description of the semantic meaning of a data asset.
However, taken together, these terms consistently
refer to the combination of syntax, structure, and
semantic meaning of a data asset. For simplicity,
this final joint rule uses the term ‘‘schema and
taxonomy’’ to refer to a description or set of
descriptions of the syntax, structure, and semantic
meaning of the data and ‘‘taxonomy’’ to refer to a
description of the semantic meaning and
hierarchical structure of data
se terms consistently
refer to the combination of syntax, structure, and
semantic meaning of a data asset. For simplicity,
this final joint rule uses the term ‘‘schema and
taxonomy’’ to refer to a description or set of
descriptions of the syntax, structure, and semantic
meaning of the data and ‘‘taxonomy’’ to refer to a
description of the semantic meaning and
hierarchical structure of data. This usage is
consistent with the definition of taxonomy in
National Information Standards Organization
Standard Z39.19, ‘‘Guidelines for the Construction,
Format, and Management of Monolingual
Controlled Vocabularies,’’ available at https://
www.niso.org/publications/ansiniso-z3919-2005-
r2010.
11 The term ‘‘data asset’’ is defined as a collection
of data elements or data sets that may be grouped
together. 44 U.S.C. 3502(17).
12 The term ‘‘open license’’ is defined as a legal
guarantee that a data asset is made available at no
cost to the public and with no restrictions on
copying, publishing, distributing, transmitting,
citing, or adapting such asset. 44 U.S.C. 3502(21).
13 Section 124(c)(2)(A) of the Financial Stability
Act.
14 Section 124(c)(2)(B) of the Financial Stability
Act.
15 FDTA section 5842 (OCC); FDTA section 5863
(Board); FDTA section 5833 (FDIC); FDTA section
TABLE 1—JOINT STANDARDS AS ESTABLISHED IN FINAL JOINT RULE—Continued
Subject matter
Standard
States, possessions, or military
‘‘states’’ of the United States or
geographic directionals.
U.S. Postal Service Abbreviations as published in Appendix B of Publication 28—Two-Letter State and
Possession Abbreviations.
Countries and their subdivisions .....
Country code with the code for subdivisions, as appropriate, as defined by the Geopolitical Entities,
Names, and Codes (GENC) developed by the Country Codes Working Group of the Geospatial Intel-
ligence Standards Working Group.
Currencies .......................................
Alphabetic currency code as defined by ISO 4217—Currency Codes
Abbreviations.
Countries and their subdivisions .....
Country code with the code for subdivisions, as appropriate, as defined by the Geopolitical Entities,
Names, and Codes (GENC) developed by the Country Codes Working Group of the Geospatial Intel-
ligence Standards Working Group.
Currencies .......................................
Alphabetic currency code as defined by ISO 4217—Currency Codes.
Data transmission and schema and
taxonomy format.
Formats that, to the extent practicable:
• Render data fully searchable and machine-readable;
• Enable high quality data through schemas, with accompanying metadata documented in machine-
readable taxonomy or ontology models, which clearly define the semantic meaning of the data, as
defined by the underlying regulatory information collection requirements, as appropriate;
• Ensure that a data element or data asset that exists to satisfy an underlying regulatory information
collection requirement be consistently identified as such in associated machine-readable metadata;
and
• Are nonproprietary or available under an open license.
A. Financial Data Transparency Act
Statutory Requirements
1. Joint Agency Rulemaking
Section 5811 of the FDTA amends
subtitle A of the Financial Stability Act
of 2010 (Financial Stability Act) 4 by
adding a new section 124.5 Section
124(b) of the Financial Stability Act
directs the Agencies to jointly issue
regulations establishing data standards
for (1) certain collections of information
reported to each Agency by financial
entities 6 under the jurisdiction of the
Agency, and (2) the data collected from
the Agencies on behalf of the Financial
Stability Oversight Council (FSOC).
Section 124 of the Financial Stability
Act defines the term ‘‘data standard’’ to
mean a standard that specifies rules by
which data is described and recorded.7
In this preamble, ‘‘joint standard’’ refers
to a data standard that has been
established by the Agencies pursuant to
the final joint rule
a collected from
the Agencies on behalf of the Financial
Stability Oversight Council (FSOC).
Section 124 of the Financial Stability
Act defines the term ‘‘data standard’’ to
mean a standard that specifies rules by
which data is described and recorded.7
In this preamble, ‘‘joint standard’’ refers
to a data standard that has been
established by the Agencies pursuant to
the final joint rule.
Section 124(c)(1)(A) of the Financial
Stability Act requires the joint standards
to include common identifiers,
including a common nonproprietary
legal entity identifier that is available
under an open license for all entities
required to report to the Agencies.
Further, section 124(c)(1)(B) of the
Financial Stability Act requires that the
data standards must, to the extent
practicable:
• Render data fully searchable and
machine-readable; 8
• Enable high quality data through
schemas, with accompanying metadata 9
documented in machine-readable
taxonomy or ontology models,10 which
clearly define the semantic meaning of
the data, as defined by the underlying
regulatory information collection
requirements;
• Ensure that a data element or data
asset 11 that exists to satisfy an
underlying regulatory information
collection requirement be consistently
identified as such in associated
machine-readable metadata;
• Be nonproprietary or made
available under an open license; 12
• Incorporate standards developed
and maintained by voluntary consensus
standards bodies; and
• Use, be consistent with, and
implement applicable accounting and
reporting principles
atisfy an
underlying regulatory information
collection requirement be consistently
identified as such in associated
machine-readable metadata;
• Be nonproprietary or made
available under an open license; 12
• Incorporate standards developed
and maintained by voluntary consensus
standards bodies; and
• Use, be consistent with, and
implement applicable accounting and
reporting principles.
Finally, section 124(c) of the
Financial Stability Act directs the
Agencies, in establishing the joint
standards, to consult with other Federal
departments and agencies and multi-
agency initiatives responsible for
Federal data standards,13 and to seek to
promote interoperability of financial
regulatory data across members of the
FSOC.14
As noted in sections I.A.2 and I.B
below, the FDTA directs the
implementing Agencies to issue
Agency-specific rulemakings adopting
applicable data standards and to
incorporate and ensure compatibility
with, to the extent feasible, the joint
standards.15 The application of the joint
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
5873 (NCUA); FDTA section 5852 (CFPB); FDTA
section 5883 (FHFA); and FDTA sections 5821,
5823, and 5824 (SEC).
16 Some Agencies already mandate the use of data
standards that are consistent with the joint
standards, and the continued application of such
standards in those contexts may not require any
new rulemaking or other action. Additionally, to
the extent an Agency applies the joint standards to
an existing collection of information not specified
in the FDTA, an Agency-specific rulemaking or
other action may not be required to incorporate the
joint standards.
17 See supra note 15.
18 Id
tandards, and the continued application of such
standards in those contexts may not require any
new rulemaking or other action. Additionally, to
the extent an Agency applies the joint standards to
an existing collection of information not specified
in the FDTA, an Agency-specific rulemaking or
other action may not be required to incorporate the
joint standards.
17 See supra note 15.
18 Id.
19 FDTA section 5843 (OCC); FDTA section 5864
(Board); FDTA section 5834 (FDIC); FDTA section
5874 (NCUA); FDTA section 5853 (CFPB); FDTA
section 5884 (FHFA); FDTA section 5826 (SEC); and
FDTA section 5813 (Treasury).
20 FDTA section 5891(c).
21 FDTA section 5841 (OCC); FDTA section
5861(a), (b), (c), (d) (Board); FDTA section 5831
(FDIC); FDTA section 5871 (NCUA); FDTA section
5851(a)(2) (CFPB); FDTA section 5881 (FHFA); and
FDTA sections 5821(a)(2), (b)(2), (c), (d), (e), (f), (g),
(h), 5823(a), 5824(a) (SEC).
22 See supra note 15.
23 Between March 2023 and the issuance of the
proposed joint rule, staff at the implementing
Agencies and Treasury consulted with counterparts
at the National Institute of Standards and
Technology, Federal Chief Data Officers Council,
Federal Evaluation Officer Council, the Federal
Financial Institutions Examination Council (FFIEC),
the Department of Health and Human Services, and
the Department of Homeland Security. These
consultations took place before the CFTC was
designated in May 2024 as a covered agency under
the FDTA.
24 Between March 2023 and the issuance of the
proposed joint rule, staff at the implementing
Agencies and Treasury consulted with the Global
Legal Entity Identifier Foundation (GLEIF),
Enterprise Data Management Council, XBRL US,
Data Foundation, and American National Standards
Institute (ANSI) Accredited Standards Committee
X9.
standards to specific collections of
information would take effect through
adoption by an Agency of an Agency-
specific rulemaking or other action.16
2
Agencies and Treasury consulted with the Global
Legal Entity Identifier Foundation (GLEIF),
Enterprise Data Management Council, XBRL US,
Data Foundation, and American National Standards
Institute (ANSI) Accredited Standards Committee
X9.
standards to specific collections of
information would take effect through
adoption by an Agency of an Agency-
specific rulemaking or other action.16
2. Agency-Specific Rulemakings
Separate from section 124 of the
Financial Stability Act, the FDTA
specifically requires each implementing
Agency to adopt by rule data standards
for certain collections of information.
Subject to the flexibilities and discretion
discussed below, the data standards that
an implementing Agency adopts in its
Agency-specific rulemaking must
incorporate and ensure compatibility
with, to the extent feasible, applicable
joint standards. Pursuant to the FDTA,
the data standards adopted by each
implementing Agency through its
respective Agency-specific rulemaking
must take effect not later than two years
after the final joint rule is
promulgated.17
Generally, in its Agency-specific
rulemaking, an implementing Agency
will determine the feasibility of
adopting and implementing the joint
standards for the collections of
information specified in the FDTA
under its purview. Additionally, in
issuing an Agency-specific rulemaking,
the FDTA specifies that each
implementing Agency (1) may scale data
reporting requirements to reduce any
unjustified burden on smaller entities
affected by the regulations and (2) must
seek to minimize disruptive changes to
those entities or persons.18 Further,
section 5891(c) of the FDTA provides
that nothing in the FDTA may be
construed to prohibit an Agency from
tailoring the data standards when those
standards are adopted. Moreover, the
FDTA does not impose new information
collection requirements
d burden on smaller entities
affected by the regulations and (2) must
seek to minimize disruptive changes to
those entities or persons.18 Further,
section 5891(c) of the FDTA provides
that nothing in the FDTA may be
construed to prohibit an Agency from
tailoring the data standards when those
standards are adopted. Moreover, the
FDTA does not impose new information
collection requirements. That is, it does
not require an implementing Agency to
collect or make publicly available
additional information that the Agency
was not already collecting or making
publicly available prior to the
enactment of the FDTA.19 Finally, an
implementing Agency retains the
discretion to decide whether the
reporting of any data field or report is
mandatory or voluntary, consistent with
applicable law.
Accordingly, in connection with an
Agency-specific rulemaking, an Agency
could determine to use an identifier that
is not in the joint standards, including
an Agency-specific identifier, rather
than, or in addition to or in combination
with, an identifier established by the
final joint rule. This could occur if, for
example, the Agency exercised its
authority to tailor the joint standards in
its Agency-specific rulemaking,20
determined either that using the
identifier established by the final joint
rule was not feasible,21 or determined
that using an identifier that is not in the
joint standards, including an Agency-
specific identifier, would minimize
disruptive changes to the persons
affected by those standards.22 In
addition, an Agency may adopt data
standards, including data standards
other than the joint standards, pursuant
to separate authority an Agency may
have.
The Agencies may work together on
the adoption of the established joint
standards in the Agency-specific
rulemakings or other Agency actions, as
appropriate
minimize
disruptive changes to the persons
affected by those standards.22 In
addition, an Agency may adopt data
standards, including data standards
other than the joint standards, pursuant
to separate authority an Agency may
have.
The Agencies may work together on
the adoption of the established joint
standards in the Agency-specific
rulemakings or other Agency actions, as
appropriate. Each Agency also expects
to monitor developments related to data
standards, including the joint standards,
and consider updating the joint
standards, as appropriate, given that the
field of data standards, data
transmission, schemas, and taxonomies
is always evolving. The individual
Agencies will interpret the final joint
rule in their individual rules and other
Agency actions.
3. Consultations
Section 124(c)(2)(A) of the Financial
Stability Act directs the Agencies to
consult with other Federal departments
and agencies and multi-agency
initiatives responsible for Federal data
standards. To comply with this
requirement, before issuing the
proposed joint rule, the implementing
Agencies and Treasury consulted with a
variety of Federal governmental entities
with relevant experience.23 The
implementing Agencies and Treasury
also met with public stakeholders with
relevant experience in advance of
issuing the proposed joint rule.24 These
consultations provided the
implementing Agencies and Treasury
with a greater understanding of the
issues involved in establishing the joint
standards.
In addition, as anticipated, the
Agencies received many public
comments on this proposed joint rule
from a wide range of stakeholders, as
described in detail below.
B. Joint Agency Establishment vs
issuing the proposed joint rule.24 These
consultations provided the
implementing Agencies and Treasury
with a greater understanding of the
issues involved in establishing the joint
standards.
In addition, as anticipated, the
Agencies received many public
comments on this proposed joint rule
from a wide range of stakeholders, as
described in detail below.
B. Joint Agency Establishment vs.
Individual Agency Adoption
As discussed in section I.A above, the
FDTA has two rulemaking
requirements: (1) a joint agency
rulemaking, in which the Agencies must
issue this final joint rule to establish the
joint standards; and (2) subsequent
Agency-specific rulemakings, in which
the implementing Agencies must
consider for adoption the specific data
standards to be used for certain
collections of information.
The joint standards, as established in
this final joint rule, are only applicable
to the Agencies themselves—they do not
change existing reporting obligations of
any person or entity and, therefore, will
not have a direct economic effect on any
person or entity. The joint standards
established by this final joint rule would
only impact persons or entities beyond
the Agencies to the extent that an
individual Agency incorporates one or
more of the joint standards into its rules
through an Agency-specific rulemaking
or other action. As discussed in section
I.A.2 above, however, establishment of
the joint standards does affect the
implementing Agencies’ obligations in
their Agency-specific rulemakings—the
FDTA requires each implementing
Agency in its Agency-specific
rulemaking to adopt data standards that
incorporate and ensure compatibility
with, to the extent feasible, applicable
joint standards established in the final
joint rule. In their Agency-specific
rulemaking or other action, the
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rulemaking to adopt data standards that
incorporate and ensure compatibility
with, to the extent feasible, applicable
joint standards established in the final
joint rule. In their Agency-specific
rulemaking or other action, the
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
25 44 U.S.C. 3501 et seq.
26 See 44 U.S.C. 3502(3) (defining ‘‘collection of
information’’).
27 See About ISO, International Organization for
Standardization, available at https://www.iso.org/
about-us.html.
28 Available at https://www.iso.org/standard/
78829.html.
29 Available at https://www.iso.org/standard/
80506.html.
30 Available at https://www.iso.org/standard/
81140.html.
31 See Standard Symbology for Global Financial
Securities, Object Management Group, available at
https://www.omg.org/figi/.
32 Available at https://www.iso.org/iso-8601-date-
and-time-format.html.
33 Available at https://pe.usps.com/text/pub28/
pub28apb.htm.
34 Available at https://www.state.gov/
independent-states-in-the-world/.
35 Available at https://www.iso.org/iso-4217-
currency-codes.html.
individual Agencies have significant
flexibility in whether and how to
incorporate the joint standards, as
discussed in section I.A.2 above.
As discussed below, some
commenters expressed the view that the
Agencies should conduct a cost-benefit
or economic analysis at this joint
rulemaking stage. In particular, various
comments asserted that (1) the joint
standards will form the economic
baseline for these subsequent Agency
actions and, thus, the economic impacts
of the joint standards will not be fully
analyzed in subsequent Agency actions,
ow, some
commenters expressed the view that the
Agencies should conduct a cost-benefit
or economic analysis at this joint
rulemaking stage. In particular, various
comments asserted that (1) the joint
standards will form the economic
baseline for these subsequent Agency
actions and, thus, the economic impacts
of the joint standards will not be fully
analyzed in subsequent Agency actions,
(2) because inclusion of common
identifiers in the joint standards will
leave little discretion to subsequent
Agency actions, the economic impact on
entities beyond Agencies can (and
should) be analyzed at the joint
rulemaking stage, or (3) failure to
consider the joint standards’ economic
impacts cannot be cured at the Agency-
specific phase.
The Agencies have considered these
comments and have determined that,
given the sequential rulemaking
structure, an analysis of the economic
effects of the joint standards for persons
or entities beyond the Agencies cannot
be meaningfully completed at this joint
rulemaking stage, because any such
analysis would depend on the future
decisions in subsequent Agency actions.
For example, without knowing whether
an Agency will incorporate a particular
joint standard in that Agency’s rules,
and if so, whether a data field related to
that standard would be required or
optional for firms to report and on
which forms or reports, it would not be
possible to evaluate the impact of that
joint standard on persons or entities
beyond that specific Agency. Relatedly,
because the Agencies retain significant
flexibility under the statute to determine
whether and how to incorporate the
joint standards in their Agency-specific
rulemakings, the Agencies disagree with
commenters who asserted that the joint
standards will limit Agency discretion
or form the economic baseline for any
subsequent Agency actions
entities
beyond that specific Agency. Relatedly,
because the Agencies retain significant
flexibility under the statute to determine
whether and how to incorporate the
joint standards in their Agency-specific
rulemakings, the Agencies disagree with
commenters who asserted that the joint
standards will limit Agency discretion
or form the economic baseline for any
subsequent Agency actions. Indeed, it is
because of this significant flexibility
that the Agencies are unable to conduct
a meaningful assessment of the
economic effects of the joint standards
at this time. The joint standards, as
established in this final joint rule, are
only applicable to the Agencies
themselves—they do not create or
change existing reporting,
recordkeeping, or other obligations of
any person or entity. Therefore, the joint
standards will not have a direct
economic effect on any person or entity.
The appropriate economic analyses
will be included when the
implementing Agencies conduct their
subsequent Agency actions, and the
public will have an opportunity at that
time to comment on all aspects of the
relevant proposals, including the joint
standards chosen and the manner of
implementation, and the associated
benefits, costs, and other economic
effects. The subsequent Agency actions,
such as Agency-specific rulemakings
and any clearances under the Paperwork
Reduction Act of 1995 (PRA) 25 for
revisions to specific information
collections, will be subject to public
comment. Given the additional steps
needed to incorporate any joint
standards into specific collections of
information, the public will have
adequate opportunity to comment on
the specific uses of the joint standards
during this subsequent implementation
stage.
C. Summary of the Proposed Joint Rule
In August 2024, the Agencies issued
for comment a proposed joint rule
implementing the statutory
requirements of the FDTA
ps
needed to incorporate any joint
standards into specific collections of
information, the public will have
adequate opportunity to comment on
the specific uses of the joint standards
during this subsequent implementation
stage.
C. Summary of the Proposed Joint Rule
In August 2024, the Agencies issued
for comment a proposed joint rule
implementing the statutory
requirements of the FDTA. In
accordance with the FDTA, the
proposed joint rule sought to promote
the interoperability of financial
regulatory data. The proposed joint rule
defined the term ‘‘collections of
information’’ by reference to the
definition of that term under the PRA.26
In the proposed joint rule, the
Agencies proposed to establish the
following data standards and sought
comment on this approach:
• ISO 27 17442—Financial Services—
LEI as the legal entity identifier joint
standard.28
• ISO 4914—Financial services—
UPI 29 for reporting of swaps and
security-based swaps, and ISO 10962—
Securities and related financial
instruments—CFI code 30 for reporting
of other types of financial instruments.
• The FIGI 31 for an identifier of
financial instruments.
• Date and time as defined by ISO
8601 32 using the Basic format option for
date fields.
• The U.S. Postal Service
Abbreviations, as published in appendix
B of Publication 28 ‘‘Postal Addressing
Standards, Mailing Standards of the
United States Postal Service,’’ 33 for the
identification of a State, possession, or
military ‘‘state’’ of the United States of
America or a geographic directional.
• Country codes and their
subdivisions, as appropriate, as defined
by the GENC standard 34 for the
identification of countries.
• The alphabetic currency code as
defined by ISO 4217 Currency Codes 35
for the identification of currencies.
The Agencies sought comment on
each of the proposed joint standards, as
well as on alternative options for each
proposed joint standard
ic directional.
• Country codes and their
subdivisions, as appropriate, as defined
by the GENC standard 34 for the
identification of countries.
• The alphabetic currency code as
defined by ISO 4217 Currency Codes 35
for the identification of currencies.
The Agencies sought comment on
each of the proposed joint standards, as
well as on alternative options for each
proposed joint standard. The Agencies
likewise sought comment on whether to
establish an additional common
identifier for Census Tract reporting as
part of the joint standards.
In addition to the common identifiers,
the proposed joint rule also sought to
establish joint standards for data
transmission and schema and taxonomy
formats. Rather than proposing any
specific data transmission or schema
and taxonomy format, the Agencies
instead identified the four properties
that a data transmission or schema and
taxonomy format should, to the extent
practicable, have. Specifically, the
Agencies proposed that the data
transmission and schema and taxonomy
format should, to the extent practicable:
(1) Render data fully searchable and
machine-readable; (2) Enable high
quality data through schemas, with
accompanying metadata documented in
machine-readable taxonomy or ontology
models, which clearly define the
semantic meaning of the data, as
defined by the underlying regulatory
information collection requirements, as
appropriate; (3) Ensure that a data
element or data asset that exists to
satisfy an underlying regulatory
information collection requirement be
consistently identified as such in
associated machine-readable metadata;
and (4) Be nonproprietary or available
under an open license. The Agencies
sought comment on the establishment of
a properties-based joint standard for
data transmission or schema and
taxonomy format, as well as the specific
properties proposed
satisfy an underlying regulatory
information collection requirement be
consistently identified as such in
associated machine-readable metadata;
and (4) Be nonproprietary or available
under an open license. The Agencies
sought comment on the establishment of
a properties-based joint standard for
data transmission or schema and
taxonomy format, as well as the specific
properties proposed.
Finally, though the Agencies
considered establishing joint standards
related to taxonomies, the proposed
joint rule did not establish a joint
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36 See supra text accompanying note 16.
37 See section II below for a discussion of the
justification for establishing each standard and
alternatives considered.
38 See 1 CFR 51.1(f).
39 See § _.2(b) of the Joint Standards.
standard related to taxonomies. Instead,
in the proposed joint rule, the Agencies
invited comment on: (1) whether to
establish a joint standard for taxonomies
based on certain properties, and if so,
the properties that should be set forth in
the joint standard; or (2) whether to
establish specific taxonomies, and if so,
the taxonomies that should be set forth
in the joint standard. The proposed joint
rule also sought comment on the use of
the term ‘‘taxonomy’’ and whether the
Agencies should define the term by rule,
and if so, how the term should be
defined. The Agencies noted that, if
after notice and comment, the final joint
rule did establish specific taxonomies as
joint standards, the implementing
Agencies would not be precluded in
their individual rulemakings from using
data element definitions from another
taxonomy or using additional
taxonomies, including Agency-specific
taxonomies, for the same collection of
information
be
defined. The Agencies noted that, if
after notice and comment, the final joint
rule did establish specific taxonomies as
joint standards, the implementing
Agencies would not be precluded in
their individual rulemakings from using
data element definitions from another
taxonomy or using additional
taxonomies, including Agency-specific
taxonomies, for the same collection of
information. The proposed joint rule
sought comment on this approach.
The Agencies emphasized in the
proposed joint rule that even when
finalized, the joint rule does not
mandate the use of any specific
standard or impose any changes to
collections of information. Rather, as
discussed in sections I.A.2 and I.B
above, the application of the joint
standards to specific collections of
information would take effect through
adoption by an Agency of an Agency-
specific rulemaking or other action.36
D. Brief Summary of Comments
Received on the Proposed Joint Rule
The Agencies received over 150
unique comments on the proposed joint
rule to establish data standards to
promote interoperability of financial
regulatory data across the Agencies,
including comments from data
standards organizations, financial and
market data businesses and consultants,
financial services firms, industry,
policy, professional and trade
associations, law firms and legal
associations, academics and researchers,
Federal, State and local governmental
entities and officials, securities
exchanges and clearing organizations,
and individuals.
Many commenters expressed support
for the goals of the FDTA and support
for the proposed joint standards.
However, some comment letters
expressed concerns with the proposed
establishment of FIGI as the common
identifier of financial instruments,
generally suggesting that the Agencies
establish no common identifier for
financial instruments
es and clearing organizations,
and individuals.
Many commenters expressed support
for the goals of the FDTA and support
for the proposed joint standards.
However, some comment letters
expressed concerns with the proposed
establishment of FIGI as the common
identifier of financial instruments,
generally suggesting that the Agencies
establish no common identifier for
financial instruments. The Agencies
received comments both in support and
in opposition, as well as comments that
asked questions or suggested alternative
options, across the proposed joint
standards, discussed in more detail
below.
1. Administrative Law Comments
Several commenters requested an
extension of the comment period,
largely focusing on the proposed
establishment of FIGI. These
commenters stated that a longer
comment period was necessary to
analyze the potential effects of FIGI’s
establishment and to gain additional
input from market participants.
Similarly, some commenters asserted
that the proposed joint rule—and
particularly the proposed establishment
of FIGI—was arbitrary and capricious
under the Administrative Procedure Act
(APA) because the Agencies did not
conduct economic and cost-benefit
analyses, provide sufficient justification
for establishing certain standards (i.e.,
FIGI), or sufficiently consider
alternative identifiers.37
In addition, a few commenters
suggested that the implementing
Agencies would be required to adopt
any standards established in the final
joint rule, and thus, economic and cost-
benefit analyses would be required at
the joint-rulemaking stage. Some
commenters also suggested that the
proposed joint rule could impose
burdens on small entities and local
governments. These commenters
requested that the Agencies exercise
scaling authority to minimize burden
and allow longer implementation
periods for such entities
n the final
joint rule, and thus, economic and cost-
benefit analyses would be required at
the joint-rulemaking stage. Some
commenters also suggested that the
proposed joint rule could impose
burdens on small entities and local
governments. These commenters
requested that the Agencies exercise
scaling authority to minimize burden
and allow longer implementation
periods for such entities.
As discussed in section II.C.2 below,
the Agencies are not establishing FIGI as
a joint standard in this rulemaking after
additional consideration and consistent
with the views expressed by many
commenters. With respect to the need
for economic and cost-benefit analyses
of the joint standards, as discussed in
section I.B, the joint standards do not
change existing reporting obligations of
any person or entity and, therefore, will
not have a direct economic effect on any
persons or entities. Moreover, given the
significant flexibility that the Agencies
retain to determine whether and how to
incorporate the joint standards, it is not
possible to meaningfully conduct those
analyses at the joint rulemaking stage.
Instead, economic analyses will be
addressed in connection with the
subsequent Agency-specific
rulemakings. Similarly, scaling
considerations for small entities and
local governments will be addressed as
part of the Agency-specific rulemaking
process, rather than at the current phase
of rulemaking to establish joint
standards
ngfully conduct those
analyses at the joint rulemaking stage.
Instead, economic analyses will be
addressed in connection with the
subsequent Agency-specific
rulemakings. Similarly, scaling
considerations for small entities and
local governments will be addressed as
part of the Agency-specific rulemaking
process, rather than at the current phase
of rulemaking to establish joint
standards.
One commenter suggested that the
proposed joint standards specify which
version of a standard, such as LEI, is
being established in order to comply
with Office of the Federal Register rules
that prohibit dynamically updating a
standard incorporated into regulation by
reference.38 However, the Agencies are
not modifying any provisions in the
final joint rule for this purpose because
the final joint rule is merely establishing
the relevant data standards, and no
member of the public will be required
to comply with, or be adversely affected
by, this final joint rule. Each Agency,
when adopting the joint standards, can
determine the level of specificity that is
necessary or appropriate in the context
of specific reporting obligations.
The final joint rule, substantially as
proposed, states that the standards will
‘‘be subject to the consideration by the
Agencies of the applicability, feasibility,
practicability, scaling, minimization of
disruption to affected persons, and
tailoring’’ as specified in the FDTA and
the Agencies therefore may tailor the
data standards they adopt, or adopt data
standards not established in the joint
standards.39 This provision makes clear
that the Agencies’ adoption of data
standards will be subject to the FDTA.
A number of commenters supported the
Agencies recognizing in the final joint
standards that, consistent with the
FDTA, the Agencies can tailor the data
standards they ultimately adopt for the
particular market participants they
regulate. Two commenters suggested
changes to the final joint rule to better
reflect this aspect of the FDTA
option of data
standards will be subject to the FDTA.
A number of commenters supported the
Agencies recognizing in the final joint
standards that, consistent with the
FDTA, the Agencies can tailor the data
standards they ultimately adopt for the
particular market participants they
regulate. Two commenters suggested
changes to the final joint rule to better
reflect this aspect of the FDTA. One of
these commenters suggested that the
final joint rule contain additional
language recognizing that the Agencies
have flexibility under the FDTA to
deviate from the joint standards in
appropriate circumstances, while the
other urged the Agencies to more
explicitly state in the final joint
standards that the Agencies are required
under the FDTA, in implementing the
joint standards, to seek to minimize
disruptions and scale requirements to
reduce unjustified burdens on small
businesses. The Agencies agree that the
final joint rule should better reflect the
Agencies’ authority to tailor the data
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40 See supra notes 20 through 22 and
accompanying text.
41 The Tower Amendment prohibits the SEC and
MSRB from requiring a municipal securities issuer
to file an application, report, or document in
connection with an issuance or sale of municipal
securities prior to the issuance or sale of those
securities. See 15 U.S.C. 78o–4(d)(1).
42 FDTA section 5823 also requires the SEC to
consult market participants when implementing the
joint standards as they apply to information
submitted to the MSRB.
43 Section 124(b) of the Financial Stability Act.
44 Specifically, the final joint rule defines
‘‘collection of information’’ as ‘‘a collection of
information as defined in the [PRA].’’ See § _.1 of
the final joint rule
(d)(1).
42 FDTA section 5823 also requires the SEC to
consult market participants when implementing the
joint standards as they apply to information
submitted to the MSRB.
43 Section 124(b) of the Financial Stability Act.
44 Specifically, the final joint rule defines
‘‘collection of information’’ as ‘‘a collection of
information as defined in the [PRA].’’ See § _.1 of
the final joint rule. The term ‘‘collection of
information’’ is defined in the PRA at 44 U.S.C.
3502(3).
45 The majority of these commenters were
concerned about the implications of the definition
on municipal markets, as discussed above. See
supra section I.D.2.
46 See Reginfo.gov, U.S. General Services
Administration and the Office of Management and
Budget, available at https://www.reginfo.gov/public.
47 The PRA definition of ‘‘collection of
information’’ includes obtaining, causing to be
obtained, soliciting, or requiring the disclosure to
third parties or the public, of facts or opinions by
or for an agency, regardless of form or format,
calling for answers to identical questions posed to,
or identical reporting requirements imposed on, ten
or more persons, other than agencies,
instrumentalities, or employees of the United
States. 44 U.S.C. 3502(3)(A)(i).
standards they adopt.40 Accordingly,
the Agencies have modified this
provision to provide, as discussed above
and in the Notice of Proposed
Rulemaking, that the Agencies may
tailor the data standards they adopt, or
adopt data standards not established in
the final joint rule.
2. Municipal Securities Market
Comments
The Agencies received several
comment letters from municipal
securities market participants. While
some of these commenters expressed
support for the goals of the FDTA, and
supported efforts to establish data
standards that promote transparency,
interoperability, and efficiency in
reporting, many municipal securities
market commenters expressed
opposition to the proposed joint rule
ents
The Agencies received several
comment letters from municipal
securities market participants. While
some of these commenters expressed
support for the goals of the FDTA, and
supported efforts to establish data
standards that promote transparency,
interoperability, and efficiency in
reporting, many municipal securities
market commenters expressed
opposition to the proposed joint rule.
Some commenters stated that the
FDTA establishes a new regulatory
framework that is inconsistent with the
10th Amendment’s preservation of
states’ rights by imposing Federal
reporting requirements on issuers of
municipal securities, infringing upon
State sovereignty, and failing to
consider principles of comity between
governmental bodies. Relatedly, some
commenters stated that the FDTA is an
unfunded Federal mandate because the
adoption of structured data and LEI
requirements might impose costs on
municipal entities without providing
corresponding funding.
Other commenters suggested that due
to a provision of the Securities Act
Amendments of 1975 commonly known
as the ‘‘Tower Amendment,’’ 41 any data
standards adopted by the SEC or the
Municipal Securities Rulemaking Board
(MSRB) under the FDTA must be
voluntary for issuers of municipal
securities. One commenter stated that
any joint standards should not apply to
information submitted to MSRB because
municipal issuers are not ‘‘financial
entities’’ and the MSRB is not a
‘‘covered agency’’ under the definitions
of those terms in the FDTA. However,
decisions regarding any data standards
applicable to information submitted to
the MSRB can only be meaningfully
addressed during the SEC-specific
rulemaking.
One commenter opposed any
interpretation of ‘‘collections of
information’’ in the final joint rule that
subjects information submitted to the
MSRB to any data standards not
developed pursuant to FDTA section
5823
he FDTA. However,
decisions regarding any data standards
applicable to information submitted to
the MSRB can only be meaningfully
addressed during the SEC-specific
rulemaking.
One commenter opposed any
interpretation of ‘‘collections of
information’’ in the final joint rule that
subjects information submitted to the
MSRB to any data standards not
developed pursuant to FDTA section
5823. Specifically, the commenter
objected to language in Footnote 17 of
the Notice of Proposed Rulemaking
stating that Agencies interpret the
directive of section 124(b)(1) of the
Financial Stability Act to apply to
specific collections of information,
including information submitted to the
MSRB under FDTA section 5823.
Another commenter referenced language
in section 5823 requiring that the
Agency-specific rulemaking incorporate
and ensure compatibility with (to the
extent feasible) the joint data standards.
The commenter interpreted this
language to indicate that the SEC should
take into account the idiosyncrasies of
the municipal securities market when
creating any joint data standard.
As discussed above, the
implementation of the joint standards as
they apply to information submitted to
the MSRB will be separately considered,
proposed, offered for comment,42 and
adopted in the Agency-specific
rulemaking pursuant to FDTA section
5823.
II. Final Joint Rule
A. Collections of Information
Under the FDTA, the joint standards
established by the final joint rule would
apply to certain collections of
information reported to each Agency.43
In the proposed joint rule, the Agencies
proposed to define the term ‘‘collections
of information’’ as used in connection
with the FDTA by reference to the
definition of that term in the PRA, an
act to which the Agencies are subject.44
One commenter expressed support for
defining ‘‘collections of information’’ in
this manner, whereas other commenters
expressed concerns about the breadth of
the definition.45 Other commenters
requested clarity as to whi
erm ‘‘collections
of information’’ as used in connection
with the FDTA by reference to the
definition of that term in the PRA, an
act to which the Agencies are subject.44
One commenter expressed support for
defining ‘‘collections of information’’ in
this manner, whereas other commenters
expressed concerns about the breadth of
the definition.45 Other commenters
requested clarity as to which collections
of information would be subject to the
proposed data standards, how those
collections would be covered, and how
the Agencies would treat ad hoc
reporting. Other commenters provided
recommendations for how the Agencies
should collect information and which
collections should be implicated by the
joint standards when they are adopted
by the Agencies.
The Agencies have considered these
comments and are establishing the
definition of ‘‘collections of
information’’ in the final joint rule as
proposed. As the Agencies explained in
the proposed joint rule, this definition
is widely understood by the Agencies
and by public stakeholders. All
approved and pending collections of
information have been categorized and
are accessible to the Agencies and the
public on Reginfo.gov.46 The use of the
term ‘‘collections of information’’ in the
FDTA is consistent with the use of the
same term in the PRA. Further, because
the PRA definition of ‘‘collections of
information’’ includes most information
that is reported to the Agencies, use of
that definition to scope the final joint
rule is consistent with the purposes of
the FDTA, which seeks to enhance the
information reported to financial
regulatory agencies.47
The Agencies have also considered
commenters’ requests to provide clarity
as to which collections of information
would be subject to the proposed data
standards, how those collections would
be covered, and how the Agencies
would treat ad hoc reporting
int
rule is consistent with the purposes of
the FDTA, which seeks to enhance the
information reported to financial
regulatory agencies.47
The Agencies have also considered
commenters’ requests to provide clarity
as to which collections of information
would be subject to the proposed data
standards, how those collections would
be covered, and how the Agencies
would treat ad hoc reporting. The
statutory language and corresponding
requirements for which collections of
information would be covered by the
FDTA’s scope vary from Agency to
Agency. As discussed above in sections
I.A.2 and I.B, each Agency expects to
address which specific collections of
information will be covered during the
Agency-specific rulemakings or other
Agency action pursuant to which joint
data standards are adopted.
The Agencies have reviewed
commenters’ recommendations for how
the Agencies should collect information
and which collections should apply
under the final joint rule. To the extent
relevant, the Agencies expect to
consider these comments when
proposing their Agency-specific
rulemakings or other Agency action
pursuant to which joint data standards
are adopted. In addition, commenters
will have the opportunity to provide
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48 See 12 U.S.C. 5334(a)(2) (FDTA reference to the
Open Government Data Act provision defining
‘‘open license’’) and 44 U.S.C. 3502(21) (definition
of ‘‘open license’’); see also supra note 12 and
accompanying text.
49 See ISO 17442: The Global Standard,
Organizational Identity, Identifying Organizations—
the Legal Entity Identifier (LEI), GLEIF—Global
Legal Entity Identifier Foundation, available at
https://www.gleif.org/en/organizational-identity/
introducing-the-legal-entity-identifier-lei/iso-17442-
the-lei-code-structure
inition
of ‘‘open license’’); see also supra note 12 and
accompanying text.
49 See ISO 17442: The Global Standard,
Organizational Identity, Identifying Organizations—
the Legal Entity Identifier (LEI), GLEIF—Global
Legal Entity Identifier Foundation, available at
https://www.gleif.org/en/organizational-identity/
introducing-the-legal-entity-identifier-lei/iso-17442-
the-lei-code-structure.
50 Section 124(c)(1)(A) of the FDTA.
51 See, e.g., LEI in Regulations, available at
https://www.gleif.org/en/lei-solutions/regulatory-
use-of-the-lei.
52 See infra note 61 (describing establishment of
the Regulatory Oversight Committee (ROC) in 2012
to oversee legal entity identification for global
financial regulatory authorities).
53 LOUs are organizations authorized to issue
LEIs to legal entities participating in financial
transactions, and also supply registration, renewal,
and other services. The LOUs are accredited by
GLEIF under ROC oversight. See https:/
www.gleif.org/en/about-lei/the-lifecycle-of-a-lei-
issuer/gleif-accreditation-of-lei-issuers.
54 The ROC was established by the FSB in
November 2012 to coordinate and oversee a
worldwide framework of legal entity identification,
the Global LEI System. See About the ROC,
Regulatory Oversight Committee, available at
https://www.leiroc.org/.
55 See generally About the FSB, Financial
Stability Board, available at https://www.fsb.org/
about/.
56 See Global LEI System, Regulatory Oversight
Committee, available at https://www.leiroc.org/
lei.htm.
57 See, e.g., ISO, Developing Standards, available
at https://www.iso.org/developing-standards.html.
58 One commenter asserted that the LEI is ‘‘not
strictly open source,’’ but the FDTA requires the
legal entity identifier be ‘‘open license’’ (as defined
by statute), not ‘‘open source.’’ See section 124(c)(1)
of the FDTA
y Oversight
Committee, available at https://www.leiroc.org/
lei.htm.
57 See, e.g., ISO, Developing Standards, available
at https://www.iso.org/developing-standards.html.
58 One commenter asserted that the LEI is ‘‘not
strictly open source,’’ but the FDTA requires the
legal entity identifier be ‘‘open license’’ (as defined
by statute), not ‘‘open source.’’ See section 124(c)(1)
of the FDTA.
59 Under the Creative Commons license CCO 1.0
Universal (CCO 1.0), GLEIF has dedicated the data
available under GLEIF’s Access Service to the
public domain, and has waived all rights
worldwide under copyright law, including all
related and neighboring rights, to the extent
allowed by law. See LEI Data Terms of Use,
available at https://www.gleif.org/en/meta/lei-data-
terms-of-use; CCO1.0 Universal (CCO 1.0), available
at https://creativecommons.org/publicdomain/zero/
1.0/.
additional feedback on affected
collections of information during the
rulemaking processes for the Agency-
specific rulemakings or other Agency
action pursuant to which joint data
standards are adopted.
B. Legal Entity Identifier
As noted in the proposed joint rule,
section 124(c)(1)(A) of the Financial
Stability Act requires that the joint
standards include ‘‘a common
nonproprietary legal entity identifier
that is available under an open license
for all entities required to report to’’ the
Agencies. The term ‘‘open license’’ is
defined by statute to mean a legal
guarantee that a data asset is made
available at no cost to the public and
with no restrictions on copying,
publishing, distributing, transmitting,
citing, or adapting such asset.48 As
proposed, the Agencies are establishing
the LEI, a global, 20-character,
alphanumeric identifier standard
documented by the ISO that uniquely
and unambiguously identifies a legal
entity, as the legal entity identifier joint
standard.49
Many commenters supported the
establishment of the LEI as the legal
entity identifier joint standard
, transmitting,
citing, or adapting such asset.48 As
proposed, the Agencies are establishing
the LEI, a global, 20-character,
alphanumeric identifier standard
documented by the ISO that uniquely
and unambiguously identifies a legal
entity, as the legal entity identifier joint
standard.49
Many commenters supported the
establishment of the LEI as the legal
entity identifier joint standard. These
commenters stated, among other things,
that the LEI meets the requirements of
the FDTA, would promote
interoperability, would provide
improved identification of entities
across jurisdictions, is already well-
established in at least some markets and
among larger financial entities, has low
costs and fees, and has a transparent
and independent governance structure.
Other commenters raised concerns that
the LEI does not meet the requirements
of the FDTA, that establishment of the
LEI would impose costs and burdens on
entities (particularly on small entities)
who would be required to obtain LEIs,
and that the LEI is not widely adopted
and not fit for purpose for some entities.
Other commenters asked questions
related to the implementation of the LEI
as the joint legal entity identifier. The
Agencies have considered these
comments, which are discussed in more
detail below, and are establishing LEI as
the legal entity identifier joint standard
in the final joint rule as proposed.
Several commenters expressed
concern that the LEI does not meet the
requirements of the FDTA. Commenters
stated, as the Agencies acknowledged in
the proposed joint rule, that entities are
required to pay a fee both initially to
obtain an LEI and annually to renew an
LEI
tail below, and are establishing LEI as
the legal entity identifier joint standard
in the final joint rule as proposed.
Several commenters expressed
concern that the LEI does not meet the
requirements of the FDTA. Commenters
stated, as the Agencies acknowledged in
the proposed joint rule, that entities are
required to pay a fee both initially to
obtain an LEI and annually to renew an
LEI. Some commenters stated that these
traits demonstrate that the LEI is neither
‘‘nonproprietary’’ nor ‘‘available under
an open license,’’ asserting that the LEI
is proprietary to Global Legal Entity
Identifier Foundation (GLEIF) and that
‘‘open license’’ as defined under the
FDTA should require that an identifier
be available at no cost to the entity
submitting the data. However, other
commenters asserted that the LEI 20-
character codes and related reference
data can be freely used, shared, and
built upon by anyone anywhere, for any
purpose. Other commenters raised
concerns that LEI is managed by GLEIF.
One commenter recommended that the
Agencies take steps designed to ensure
that GLEIF is not using revenue from
LEI for any purpose other than operating
the system. Another commenter seemed
to suggest that GLEIF may not be a
voluntary consensus standards body.
Some commenters also raised concerns
with mandating the use of a standard
that is dependent on, and requires
payment to, a foreign entity
menter recommended that the
Agencies take steps designed to ensure
that GLEIF is not using revenue from
LEI for any purpose other than operating
the system. Another commenter seemed
to suggest that GLEIF may not be a
voluntary consensus standards body.
Some commenters also raised concerns
with mandating the use of a standard
that is dependent on, and requires
payment to, a foreign entity.
The LEI meets all of the FDTA’s
requirements for legal entity identifiers,
that is, it is common, nonproprietary,
and is available under an open
license.50 The LEI is common because it
is used worldwide in the private and
public sectors and, in certain
jurisdictions, including in the United
States, is currently used for some
regulatory reporting.51 The LEI is
nonproprietary because it is overseen by
an independent body composed of
regulators and other public authorities
with a goal that the data be freely
available to all.52 Specifically, GLEIF
and the local operating units (LOUs) 53
are overseen by the Regulatory
Oversight Committee (ROC),54 which
consists of financial markets regulators,
other public authorities, and observers
from more than 50 countries. ROC’s
charter asserts that an objective of the
ROC is to ensure that LEI data be
nonproprietary, with no restrictions on
access, usage, or redistribution, and that
all LEI data should be readily available
on a continuous basis, easily and widely
accessible using modern technology,
and free of charge.
Commenter concerns about GLEIF are
addressed by the oversight to which
GLEIF is subject, including by regulators
in the United States as members of the
ROC. GLEIF was established by the
Financial Stability Board (FSB) in June
2014 to support the implementation and
use of the LEI.55 GLEIF must adhere to
governance principles designed by the
FSB and the ROC. The United States is
currently represented by the Treasury’s
Office of Financial Research (OFR), SEC,
Board, CFPB, OCC, CFTC, and FDIC, all
serving as members on the ROC
embers of the
ROC. GLEIF was established by the
Financial Stability Board (FSB) in June
2014 to support the implementation and
use of the LEI.55 GLEIF must adhere to
governance principles designed by the
FSB and the ROC. The United States is
currently represented by the Treasury’s
Office of Financial Research (OFR), SEC,
Board, CFPB, OCC, CFTC, and FDIC, all
serving as members on the ROC. The
FSB assigned responsibility for
maintenance of LEI to GLEIF and
established the ROC to set broad policy
objectives for GLEIF and oversee its
work so that it adheres to established
governance principles designed to
represent the public interest.56 Further,
the ISO, which documents the LEI
standard, is a voluntary consensus
standards body.57
The LEI is also open license as
required by the FDTA.58 GLEIF’s LEI
data terms of use declares that users can
freely download LEIs and LEI data,
which are available under a Creative
Commons license that permits the
public to obtain LEI reference data
conveniently and free of charge.59 The
LEI is thus available under an open
license even though entities to whom an
LEI is assigned must pay a fee to obtain
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60 All LOUs are subject to GLEIF’s Master
Agreement, which requires LEIs be made non-
proprietary, and freely and openly available. Master
Agreement available at https://www.gleif.org/en/
organizational-identity/the-lifecycle-of-a-lei-issuer/
gleif-accreditation-of-lei-issuers/required-
documents#
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60 All LOUs are subject to GLEIF’s Master
Agreement, which requires LEIs be made non-
proprietary, and freely and openly available. Master
Agreement available at https://www.gleif.org/en/
organizational-identity/the-lifecycle-of-a-lei-issuer/
gleif-accreditation-of-lei-issuers/required-
documents#.
61 See Charter of the ROC For the Global Legal
Entity Identifier System and Governance of Certain
Other Global Data Identifiers and Elements at
2.a.(2).ii, available at https://www.leiroc.org/
publications/gls/roc_20201001-1.pdf#page=27
(stating as an objective of the ROC to be, among
other things, to provide that fees are set on a non-
profit cost-recovery basis); Global Legal Entity
Identifier Foundation, Statutes of August 7, 2018,
available at https://www.gleif.org/about/
governance/statutes/gleif-20180807.pdf (GLEIF
Statutes) (stating that where fees are imposed with
relation to the LEI they be modest and based on a
cost-recovery basis that avoids monopoly rents).
62 See, e.g., https://rapidlei.com/.
63 See also supra section I.D.2 (discussing
comments raised in the context of the municipal
securities markets, including some that relate to the
LEI).
64 A framework for renewal is established by the
Master Agreement of the Global LEI System
between the LOUs and GLEIF. See Master
Agreement, Rev. 1.4.1 (26 June 2024), Global Legal
Entity Identifier Foundation, available at https://
www.gleif.org/en/about-lei/the-lifecycle-of-a-lei-
issuer/gleif-accreditation-of-lei-issuers/required-
documents.
65 See supra sections I.B and I.D.1.
66 For example, regarding some of the filings
made with the SEC, Form ADV and Form N–PX
allow for disclosure of the LEI if available. Form N–
CEN, Form N–PORT, and Form N–MFP require
disclosure of the LEI for the registrant and series but
allow for LEI disclosure in other contexts
of-a-lei-
issuer/gleif-accreditation-of-lei-issuers/required-
documents.
65 See supra sections I.B and I.D.1.
66 For example, regarding some of the filings
made with the SEC, Form ADV and Form N–PX
allow for disclosure of the LEI if available. Form N–
CEN, Form N–PORT, and Form N–MFP require
disclosure of the LEI for the registrant and series but
allow for LEI disclosure in other contexts. See, e.g.,
Form ADV, part 1A, Item 1.P, section 5.K.(3), and
section 7.B.(1)(A)(25)(g); Form N–PX Cover Page;
Form N–CEN, part C: Item C.3.f.i.2.C, Item
C.3.f.i.3.B, and Item C.5.b.ii (if any); Form N–PORT,
Item A.1.d., Item A.2.c., Item B.4.a.ii. (if any), Item
C.1.b., Item C.10.b.ii., and Item C.11.b.i.; and Form
N–MFP, Item 4 and Item 6.
67 See ISO 17442–3:2024, Financial services—
Legal Entity Identifier (LEI), part 3: Verifiable LEIs
(vLEIs), International Organization for
Standardization, available at https://www.iso.org/
standard/85628.html.
or renew an LEI.60 In addition, the fees
imposed by GLEIF and LOUs on legal
entities that register and renew their
LEIs are based on the cost-recovery
principle, whereby fees must not be
higher than necessary to recover an
LOU’s costs and are intended to remove
a potential profit motive as an influence
on their LEI activities.61 The GLEIF
Statutes also state that the cost of
obtaining an LEI should be modest and
not a barrier to acquisition and not
bundled with other services. In the
United States, the Agencies understand
that these fees are approximately
between $50 to $100 for registration and
the same annually for renewal of an
individual LEI.62 Also, LOUs compete
with each other, and some LOUs have
reduced their fees in response to this
competition. Lastly, the Agencies
understand that GLEIF continues to
explore vehicles for systematically
reducing the costs for entities obtaining
LEIs such as multiyear issuance
agreements, bulk registration, and
registration agents
ion and
the same annually for renewal of an
individual LEI.62 Also, LOUs compete
with each other, and some LOUs have
reduced their fees in response to this
competition. Lastly, the Agencies
understand that GLEIF continues to
explore vehicles for systematically
reducing the costs for entities obtaining
LEIs such as multiyear issuance
agreements, bulk registration, and
registration agents.
Commenters also raised concerns
about costs beyond those to obtain an
LEI and other challenges that could
arise depending on how the Agencies
adopt the joint standard.63 Specifically,
some commenters identified concerns
with additional direct and indirect costs
borne by the entities, such as the costs
of updating systems, training, hiring
external experts, and conducting
compliance outreach efforts. Some
commenters asserted that LEI is not
widely adopted, especially among
smaller entities, non-profit
organizations, municipal entities, and
foreign entities. Some commenters
further requested that the Agencies
specifically consider potential costs to
small- and medium-sized entities. In
addition to concerns about costs, several
commenters expressed opposition to the
possibility that the Agencies might
apply the LEI standard to entities that
are not related to the filer of a given
report (i.e., third parties such as clients,
counterparties or service providers) to
produce an LEI for Agencies’
information collections. Different
commenters noted that obtaining LEIs
from a regulated entity’s clients,
counterparties, and other third parties
would present special challenges, and
that certain entities or parties would be
unable to obtain an LEI
d to the filer of a given
report (i.e., third parties such as clients,
counterparties or service providers) to
produce an LEI for Agencies’
information collections. Different
commenters noted that obtaining LEIs
from a regulated entity’s clients,
counterparties, and other third parties
would present special challenges, and
that certain entities or parties would be
unable to obtain an LEI. Some
commenters stated that the
establishment of LEI would be
inappropriate because certain entities
cannot obtain an LEI, including natural
persons who are acting in a non-
business capacity and sole
proprietorships and general
partnerships in certain states, or because
the LEI does not properly identify the
obligated parties (or component entities
or specific credits thereof, which may be
the sole source of repayment for the
securities but may not be separate legal
entities) involved in municipal
securities offerings. Some commenters
also raised the concern that the
establishment of LEI has the potential to
create unverifiable legal entities or
create confusion about such entities’
obligations. Some commenters
requested that the Agencies specify that
an LEI that has not been renewed, as is
required annually, may still be used in
collections of information.64
Although the Agencies appreciate
these concerns, establishing the LEI in
the joint standards does not create any
new costs or otherwise impact any
collection of information or third party
as the final joint rule does not mandate
the use of any specific standard or
impose any changes to collections of
information.65 The concerns raised by
these commenters would only arise to
the extent that an Agency decides to
adopt the joint LEI standard into its
rules through an Agency-specific
rulemaking or other action. Even then,
the Agencies retain significant
discretion in how they adopt the joint
standards, including tailoring any
collection of information consistent
with the requirements of the FDTA
ion.65 The concerns raised by
these commenters would only arise to
the extent that an Agency decides to
adopt the joint LEI standard into its
rules through an Agency-specific
rulemaking or other action. Even then,
the Agencies retain significant
discretion in how they adopt the joint
standards, including tailoring any
collection of information consistent
with the requirements of the FDTA. For
example, as suggested by commenters,
collections of information could (and in
some cases currently do) allow for other
entity identifiers, specify that a
reporting entity need only report an LEI
if the entity has one, and permit LEIs
that have lapsed to nonetheless be
reported.66 Further, the Agencies have
the discretion to determine to what
extent entities are obligated to renew
their LEIs and update their
corresponding legal entity reference
data as an LEI that has not been
renewed can still identify an entity.
Several commenters recommended
other legal entity identifiers or identifier
standards. These include ISO 8000–116,
the ISO standard for formatting
Authoritative Legal Entity Identifiers
(ALEI) as International Business
Registration Numbers (IBRN). ALEI
refers to an entity identifier used in an
authoritative source, such as a
jurisdiction business registry, where an
entity is already registered. Some
commenters recommended other legal
entity identifiers, including the
verifiable LEI (vLEI).67 The vLEI is a
GLEIF identifier that GLEIF presents as
a digitally trustworthy version of the 20-
digit LEI code which is automatically
verifiable, without the need for human
intervention. Other commenters
recommended identifiers issued by the
U.S. Federal or State governments such
as the SEC’s Central Index Key; FINRA’s
Central Registration Depository
numbers, IRS Employer/Taxpayer
Identification Numbers, and Delaware
Division of Corporations File Numbers
stworthy version of the 20-
digit LEI code which is automatically
verifiable, without the need for human
intervention. Other commenters
recommended identifiers issued by the
U.S. Federal or State governments such
as the SEC’s Central Index Key; FINRA’s
Central Registration Depository
numbers, IRS Employer/Taxpayer
Identification Numbers, and Delaware
Division of Corporations File Numbers.
The Agencies have considered these
comments and the legal entity identifier
options proposed by the commenters,
and determined not to establish
alternative or additional legal entity
identifiers as part of the joint standards
because the LEI best meets the
requirements of the FDTA for the
reasons discussed above. However, as
also discussed above, the individual
Agencies have significant flexibility in
whether and how to adopt the standards
in the future in their Agency-specific
rulemaking or other action and may
consider them as replacements or
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68 See supra sections I.B and I.D.1.
69 See also Standard Symbology for Global
Financial Securities, Object Management Group,
available at https://www.omg.org/figi/ for a
description of FIGI.
70 See supra at section I.A
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68 See supra sections I.B and I.D.1.
69 See also Standard Symbology for Global
Financial Securities, Object Management Group,
available at https://www.omg.org/figi/ for a
description of FIGI.
70 See supra at section I.A. Section 124(c)(1)(B)
specifies the six criteria, which are to: (i) render
data fully searchable and machine-readable; (ii)
enable high quality data through schemas, with
accompanying metadata documented in machine-
readable taxonomy or ontology models, which
clearly define the semantic meaning of the data, as
defined by the underlying regulatory information
collection requirements; (iii) ensure that a data
element or data asset that exists to satisfy an
underlying regulatory information collection
requirement be consistently identified as such in
associated machine-readable metadata; (iv) be
nonproprietary or made available under an open
license; (v) incorporate standards developed and
maintained by voluntary consensus standards
bodies; and (vi) use, be consistent with, and
implement applicable accounting and reporting
principles. The statute also states, among other
things, that in establishing data standards the
Agencies must seek to promote interoperability of
financial regulatory data across members of the
FSOC.
71 See supra note 12 and accompanying text.
72 The proposed joint rule stated that Bloomberg
L.P., which irrevocably contributed its FIGI
intellectual property to OMG, continues to function
as a registration authority for FIGI issuances.
alternatives to the LEI at that time
consistent with the requirements of the
FDTA.68
C. Other Common Identifiers
1
ory data across members of the
FSOC.
71 See supra note 12 and accompanying text.
72 The proposed joint rule stated that Bloomberg
L.P., which irrevocably contributed its FIGI
intellectual property to OMG, continues to function
as a registration authority for FIGI issuances.
alternatives to the LEI at that time
consistent with the requirements of the
FDTA.68
C. Other Common Identifiers
1. Unique Product Identifier (UPI) and
Classification of Financial Instruments
(CFI)
In the proposed joint rule, the
Agencies proposed to establish ISO
4914—Financial services—Unique
product identifier (UPI) as the common
identifier for reporting of swaps and
security-based swaps. For other types of
financial instruments, the Agencies
proposed to establish ISO 10962—
Classification of financial instruments
(CFI) code. The UPI and CFI are useful
for aggregating data and increasing
global transparency, which is beneficial
in certain financial markets such as
swaps, forwards, and non-listed options.
After considering the comments
received, the Agencies are establishing
the UPI and CFI as standards in the final
joint rule, as proposed, with one change
based on commenter feedback as
discussed below.
Commenters largely supported
establishing both the UPI and CFI
standards. These commenters
highlighted that both standards are
taxonomic systems for financial
instruments that are useful for
aggregating data and increasing global
transparency. Regarding UPI, some of
these commenters observed that it is
already a required data element under
some established SEC, FDIC, Treasury,
and CFTC rules. Another remarked that
the UPI was driven by global regulators
and was the result of years-long
consultation, planning, and analysis.
This commenter further stated that
establishing UPI would be a key step
toward global aggregation of over-the-
counter derivatives transaction data
served that it is
already a required data element under
some established SEC, FDIC, Treasury,
and CFTC rules. Another remarked that
the UPI was driven by global regulators
and was the result of years-long
consultation, planning, and analysis.
This commenter further stated that
establishing UPI would be a key step
toward global aggregation of over-the-
counter derivatives transaction data.
Regarding CFI, one of the supportive
commenters highlighted how the CFI is
useful for a number of financial
instruments.
The Agencies proposed to establish
the CFI for the identification of financial
instruments that are not swaps or
security-based swaps. Several
commenters observed that the CFI is a
classification, not identification, system
and questioned how one would use CFI
to identify a financial instrument. For
example, in the context of an equity
security, CFI has a separate category
identifier, ‘‘E’’, for equity securities
generally and enables further
classification into groups of equity
securities such as ‘‘P’’ for preferred
shares. CFI thus allows for the
classification of equities as a category as
in this example, but does not provide a
means to ‘‘identify’’ any specific equity
security (that is, all preferred shares
from all issuers would use the same ‘‘E’’
and ‘‘P’’ classifications so there would
be no way to distinguish amongst them).
Given this, the Agencies are establishing
the use of the CFI in the final joint
standards to classify financial
instruments, not to identify them.
While no commenters raised any
concerns with regard to the
establishment of UPI, some did with the
establishment of CFI. One commenter
suggested that while it did not object to
the use of CFI generally, the CFI code
was not readily available and posed data
quality risks because there is no official
assigning body for CFI codes
ards to classify financial
instruments, not to identify them.
While no commenters raised any
concerns with regard to the
establishment of UPI, some did with the
establishment of CFI. One commenter
suggested that while it did not object to
the use of CFI generally, the CFI code
was not readily available and posed data
quality risks because there is no official
assigning body for CFI codes. This
commenter encouraged the Agencies to
make a list of approved assigning bodies
or require the issuer of a security be the
entity to assign the CFI code for
consistency. Given that both CFI and
UPI are supported through the open
standards organizations of ASC X9 and
ISO, their content (and any need for
potential updates) can be assessed by
these organizations every five years in
collaboration with industry. Further,
CFI codes without these additional
limitations are currently used in CFTC
reporting, as other commenters noted.
Another commenter stated that well-
established incumbent identifiers other
than CFI are already fully integrated
into relevant systems. As explained
above, the final joint standards establish
the use of CFI to categorize, not identify,
relevant financial instruments. Further,
the Agencies recognize that there are
myriad ways to classify (or identify)
financial instruments at use within
transactional systems, across many
diverse financial products, with many
use cases, and various degrees of market
penetration. This is one of the
compelling reasons to establish the CFI.
It allows for mapping a wide variety of
financial instruments across different
markets, with established mappings for
each type of instrument. Each Agency
will have discretion in its own Agency-
specific rulemakings to consider the
benefits and costs of requiring CFI in
specific collections of information.
2
market
penetration. This is one of the
compelling reasons to establish the CFI.
It allows for mapping a wide variety of
financial instruments across different
markets, with established mappings for
each type of instrument. Each Agency
will have discretion in its own Agency-
specific rulemakings to consider the
benefits and costs of requiring CFI in
specific collections of information.
2. Financial Instrument Global Identifier
(FIGI) and Other Financial Instruments
Identifiers
The Agencies proposed to establish
the FIGI as the identifier for financial
instruments (FIGI proposal).69 The
proposed joint rule stated that each of
the proposed identifiers, including FIGI,
satisfies the requirements listed in
section 124(c)(1) of the Financial
Stability Act, which, as discussed
above, requires the joint standards to
include common identifiers for
collections of information reported to
the Agencies or collected on behalf of
the FSOC that, to the extent practicable,
meet the requirements of six specified
criteria.70 After considering comments
and in a change from the proposed joint
rule, the Agencies are not establishing
FIGI as a joint standard in this
rulemaking, as discussed further below.
The proposed joint rule described
certain aspects of FIGI that meet two of
the criteria, specifically, the
requirements: (1) to be nonproprietary
or made available under an open
license; 71 and (2) to incorporate
standards developed and maintained by
voluntary consensus standards bodies.
Specifically, the proposed joint rule
stated that FIGI is a global, non-
proprietary identifier for all classes of
financial instruments, including, but not
limited to, securities and digital assets,
that is available under an open license.
The proposed joint rule also explained
that FIGI’s intellectual property is
owned by Object Management Group
(OMG), an open-membership standards
consortium, and stated that FIGI has
been implemented as a U.S
a global, non-
proprietary identifier for all classes of
financial instruments, including, but not
limited to, securities and digital assets,
that is available under an open license.
The proposed joint rule also explained
that FIGI’s intellectual property is
owned by Object Management Group
(OMG), an open-membership standards
consortium, and stated that FIGI has
been implemented as a U.S. standard
(X9.145) by the ANSI Accredited
Standards Committee X9 organization.72
In proposing to establish FIGI as the
common financial instrument identifier,
the Agencies noted that they had also
considered identifiers established by the
Committee on Uniform Securities
Identification Procedures (CUSIP
numbers) and the ISIN (which includes
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73 See supra section I.D (discussing comments
received regarding the costs and benefits of the
proposed joint standards).
74 For information regarding the free availability
of FIGI under an open MIT license, see https://
opensource.org/license/mit; https://
www.openfigi.com/assets/local/figi-allocation-
rules.pdf.
CUSIP numbers). The Agencies stated
that, while these identifiers are widely
used, they are proprietary and not
available under an open license in the
United States.
The Agencies received significant
comment on the FIGI proposal, with a
notable divergence in commenters’
views both in support of and against the
FIGI proposal. Some commenters
generally supported the FIGI proposal
on the grounds that FIGI meets the
statutory criteria and would further the
FDTA’s goal of promoting
interoperability among the Agencies.
Moreover, certain commenters who
supported the FIGI proposal contrasted
FIGI with other identifiers, such as
CUSIP numbers, which they stated did
not meet the FDTA’s statutory criteria
IGI proposal. Some commenters
generally supported the FIGI proposal
on the grounds that FIGI meets the
statutory criteria and would further the
FDTA’s goal of promoting
interoperability among the Agencies.
Moreover, certain commenters who
supported the FIGI proposal contrasted
FIGI with other identifiers, such as
CUSIP numbers, which they stated did
not meet the FDTA’s statutory criteria.
Many commenters opposed the FIGI
proposal based on objections that
included the lack of a statutory
requirement to establish—or need for—
a financial instrument common
identifier, as well as potential
operational and other burdens
associated with reporting FIGI. Some of
these commenters also asserted that the
Agencies should have undertaken a
cost-benefit analysis in connection with
establishing FIGI in the joint standards
as a common identifier at the joint
Agency rulemaking stage, in addition to
the Agency-specific rulemaking stage,
and that the failure to do so raises
concerns under the APA.73
Comments were mixed regarding
nearly every aspect of the FIGI proposal.
Several commenters who supported
establishing FIGI as a joint standard in
the final joint rule cited certain
attributes of the FIGI standard in
support of their position, including the
lack of license restrictions on the use,
reuse, and distribution of FIGIs. Some
commenters generally stated that the
FIGI standard is nonproprietary because
it is owned and maintained by and
made available under an open license
by OMG, a voluntary standards body.74
Commenters also asserted that no
license is required to view, download,
and use FIGI; FIGI is free of charge for
use by all market participants with no
commercial terms or restrictions on
usage; and all of the FIGI reference data
elements are available in the public
domain. However, other commenters
disputed whether FIGI is available
under an open license, nonproprietary,
and/or available free of charge in
practice
no
license is required to view, download,
and use FIGI; FIGI is free of charge for
use by all market participants with no
commercial terms or restrictions on
usage; and all of the FIGI reference data
elements are available in the public
domain. However, other commenters
disputed whether FIGI is available
under an open license, nonproprietary,
and/or available free of charge in
practice. For example, some of these
commenters stated that the FIGI
identifier that is freely available on
OpenFIGI.com cannot be used
effectively for certain securities for
which OpenFIGI’s freely available
reference data is insufficient to uniquely
identify these securities without
additional information from a paid
subscription service or payment to a
third-party.
Some commenters stated that the FIGI
standard is developed and maintained
by voluntary standards bodies. Other
commenters asserted that FIGI may not
satisfy the criteria because it was
developed by Bloomberg L.P., which is
not a voluntary consensus standards
body, and did not go through a process
that involved the input of other market
participants. Some commenters
questioned whether OMG is sufficiently
independent of Bloomberg L.P. to
constitute a voluntary consensus body,
while others observed that FIGI has not
been adopted by certain other voluntary
consensus standards bodies. Other
commenters asserted that any concerns
about the origins of FIGI have been
addressed through the transfer of the
FIGI standard to OMG and the
establishment of an open and free
license. Some commenters also asserted
that establishing FIGI as a joint standard
may, among other things, undermine
fair competition among data vendors,
give Bloomberg L.P. an unfair
competitive advantage and result in
barriers to entry for other market
participants
ns of FIGI have been
addressed through the transfer of the
FIGI standard to OMG and the
establishment of an open and free
license. Some commenters also asserted
that establishing FIGI as a joint standard
may, among other things, undermine
fair competition among data vendors,
give Bloomberg L.P. an unfair
competitive advantage and result in
barriers to entry for other market
participants. Conversely, other
commenters stated that because FIGI is
non-proprietary, it reduces barriers to
entry associated with proprietary
identifiers such as CUSIP numbers,
which some commenters asserted are
subject to onerous licensing restrictions,
and limits equitable participation,
innovation, and efficiency across the
financial industry, particularly for
smaller firms and fintech innovators.
Further, some commenters asserted that
CUSIP Global Services operates CUSIP
numbers as a monopoly and that
adopting FIGI would better serve the
public consistent with Congressional
intent.
Commenters also discussed FIGI’s
fitness for use as a financial instrument
identifier for Federal reporting
purposes. Some commenters asserted
that adopting a common, freely
available and restriction-free financial
instrument identifier across the
financial regulatory system would
enhance the Agencies’ ability to collect
and manage data reported by regulated
and supervised entities, and enable the
Agencies to be more effective at
identifying and remedying threats to
consumers, markets, and overall
financial systemic stability. These
commenters cited the fact that each
financial instrument is assigned a
unique FIGI that identifies a security no
matter where it trades (share class FIGI),
as well as more granular versions that
identify the country in which it trades
(country composite FIGI) and the
exchange on which it is traded
(exchange level FIGI) in support of its
fitness for use as a common identifier
for regulatory purposes
cited the fact that each
financial instrument is assigned a
unique FIGI that identifies a security no
matter where it trades (share class FIGI),
as well as more granular versions that
identify the country in which it trades
(country composite FIGI) and the
exchange on which it is traded
(exchange level FIGI) in support of its
fitness for use as a common identifier
for regulatory purposes. Opposing
commenters questioned whether the
level of detail required for regulatory
reporting could be done with only open-
source FIGI information, and suggested
that the complexity of the additional
granularity would likely introduce
errors.
Several commenters raised questions
about FIGI’s fungibility (broadly
characterized by commenters to mean
that a specific security has the same
identifier regardless of where it trades).
Some commenters said FIGI generally is
not fungible or interchangeable with
other identifiers, such as CUSIP
numbers, because although each
security has one CUSIP number, it can
have multiple FIGIs, which may result
in confusion and errors. Other
commenters stated that FIGI is fungible
because the equity share class FIGI
identifies the listed company regardless
of the country and the exchange on
which the shares trade, and in non-
equity asset classes, the base level FIGI
serves the same capacity. These
commenters also stated that all FIGIs at
exchange-level or country composite
roll up to the share class level.
Some commenters stated that one of
FIGI’s advantages over other security
identifiers is that it is a unique identifier
that does not change, regardless of
corporate action, is never recycled for
use in new financial instruments, and
can serve as a historical reference for
retired or obsolete financial
instruments
s at
exchange-level or country composite
roll up to the share class level.
Some commenters stated that one of
FIGI’s advantages over other security
identifiers is that it is a unique identifier
that does not change, regardless of
corporate action, is never recycled for
use in new financial instruments, and
can serve as a historical reference for
retired or obsolete financial
instruments. Commenters who opposed
FIGI suggested that this aspect of FIGI
is undesirable because FIGI does not
allow for differentiation of securities
before or after corporate actions such as
mergers or stock splits, and stated that
to the extent that corporate actions are
treated differently under the ISIN/
CUSIP number and FIGI specifications,
there may not always be a one-to-one
mapping between ISIN/CUSIP number
and FIGI, which may lead to confusion
and errors when reporting information
about financial instruments to the
Agencies.
Regarding mapping, some
commenters stated that a free mapping
application is available to help access
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data and facilitate the matching of FIGI
with other identifiers. Other
commenters said the availability of this
open mapping service would facilitate
FIGI implementation without expensive
replacement of internal processing
systems and applications, which would
enhance market efficiency,
transparency, and interoperability.
Several commenters suggested that
mapping to FIGI may not be possible or
that, although mapping to FIGI may be
possible, it may be challenging given,
for example, the varying levels of FIGI
granularity.
Commenters expressed varying views
regarding the scope of FIGI’s asset
coverage
sing
systems and applications, which would
enhance market efficiency,
transparency, and interoperability.
Several commenters suggested that
mapping to FIGI may not be possible or
that, although mapping to FIGI may be
possible, it may be challenging given,
for example, the varying levels of FIGI
granularity.
Commenters expressed varying views
regarding the scope of FIGI’s asset
coverage. Certain commenters stated
that FIGI offers global asset class
coverage for nearly all asset classes,
including for fixed income, currency
futures, cryptocurrencies, crypto assets,
indices, and commodity futures.
Conversely, other commenters asserted
that FIGIs are not sufficiently available
for certain asset classes/financial
instruments, such as loans and
municipal bonds. Some commenters
stated that FIGI provides real-time
availability, while others indicated that
there are typically delays in obtaining a
FIGI for municipal or newly issued
financial instruments.
Comments were also mixed regarding
the extent to which FIGI is used by
market participants. Opposing
commenters claimed that FIGI is not
widely used by regulated entities and
financial market utilities for domestic
securities transactions, clearance,
settlement, and reporting, in contrast to
ISIN/CUSIP numbers. Others stated that
FIGI is widely used and provided
evidence of the widespread market use
of FIGI based on the high volume of
monthly downloads of FIGI data from
the OpenFIGI.com Application
Programming Interface and the fact that
data vendors worldwide use FIGI as a
security identifier option.
Commenters who opposed the
proposal to establish FIGI as a financial
instrument identifier cited other reasons
for their opposition. Certain
commenters asserted that the statute
does not require the Agencies to
establish a financial instrument
identifier and stated that the proposed
joint rule does not articulate a need to
do so
endors worldwide use FIGI as a
security identifier option.
Commenters who opposed the
proposal to establish FIGI as a financial
instrument identifier cited other reasons
for their opposition. Certain
commenters asserted that the statute
does not require the Agencies to
establish a financial instrument
identifier and stated that the proposed
joint rule does not articulate a need to
do so. Others questioned whether the
proposal to establish FIGI as a joint
standard was within the statutory
mandate of the FDTA or otherwise
consistent with Congressional intent.
Conversely, some claimed that the
proposal to establish FIGI was well
within the statutory mandate, and the
statute did not restrict the types of
common identifiers that could be joint
standards. Several commenters stated
that the statute does not require any
data standards (other than the legal
entity identifier) to be nonproprietary
and made available under an open
license. Other commenters asserted that
the fact that the statute specifically
mandates these criteria for legal entity
identifiers does not restrict regulators
from applying the same standard to
other common identifiers, including
financial instrument identifiers. Several
commenters asserted that, because the
statutory criteria specified for non-legal
entity identifier data standards only
apply ‘‘to the extent practicable,’’ the
Agencies should not have evaluated
potential financial instrument
identifiers based solely on two
particular factors.
Many commenters stated that the
proposed joint rule failed to sufficiently
evaluate the need for a new financial
instrument identifier given that CUSIP
numbers/ISIN are historically and
currently required to be reported as
financial instrument identifiers in some
of the Agencies’ existing rules and
forms
potential financial instrument
identifiers based solely on two
particular factors.
Many commenters stated that the
proposed joint rule failed to sufficiently
evaluate the need for a new financial
instrument identifier given that CUSIP
numbers/ISIN are historically and
currently required to be reported as
financial instrument identifiers in some
of the Agencies’ existing rules and
forms. Several commenters asserted that
the proposed joint rule failed to
properly consider CUSIP numbers/ISIN
as a common financial instrument
identifier, particularly in light of these
instruments’ pervasive use in the
financial industry coupled with the
potential for significant market
disruption were FIGI to be established
as a common identifier for purposes of
regulatory reporting. Other commenters,
while acknowledging that CUSIP
numbers are widely used in the
infrastructure of financial systems,
stated that establishing FIGI as a
required standard for Federal reporting
purposes would not change current
trading and settlement practices nor
lead to widespread market disruptions.
Some commenters asserted that the
Agencies should conduct a more
thorough investigation and analysis
before establishing FIGI as a joint
standard, including more engagement
with market participants.
Many commenters discussed the
potential costs and burdens associated
with establishing FIGI as a joint
standard. Some commenters asserted
that, although FIGI may not have a
licensing cost, any requirement to
modify internal systems and processes
to incorporate FIGI as a financial
instrument identifier for purposes of
reporting FIGI to the Agencies would be
expensive and burdensome, requiring a
major transformation to how the
financial services industry manages
data, with some stating that adopting
FIGI is not practicable
that, although FIGI may not have a
licensing cost, any requirement to
modify internal systems and processes
to incorporate FIGI as a financial
instrument identifier for purposes of
reporting FIGI to the Agencies would be
expensive and burdensome, requiring a
major transformation to how the
financial services industry manages
data, with some stating that adopting
FIGI is not practicable. In particular,
several commenters stated that requiring
firms to report a financial instrument
identifier that is not currently widely
used in the financial markets would be
highly costly and disruptive due, among
other things, to the need to undertake an
extensive mapping exercise to
incorporate FIGI. Some commenters
stated that establishing FIGI as a joint
standard would necessitate redundant
and overlapping systems because CUSIP
numbers would still be needed. Certain
commenters expressed concerns about
the potential cost impact of FIGI
adoption on smaller entities. Further,
some commenters asserted that the
Agencies should carefully study
whether the expected benefits of the
proposed joint rule outweigh the
expected costs before selecting a new
identifier. Conversely, other
commenters disputed the stated cost
concerns, asserting that transitioning to
FIGI would involve minimal operational
adjustments and that long-term benefits
would outweigh short-term challenges.
Some commenters also pointed out that
FIGI has already been adopted as a
security identifier for certain U.S.
regulatory reporting requirements.
Certain commenters also highlighted the
significant challenges smaller firms face
under the existing regulatory
requirements due to the costs associated
with using CUSIP numbers.
After considering comments, and
given the nature of the issues raised by
commenters on the proposal to establish
FIGI, as well as the notable divergence
in commenters’ views, the Agencies are
not establishing FIGI as a joint standard
in this rulemaking
ignificant challenges smaller firms face
under the existing regulatory
requirements due to the costs associated
with using CUSIP numbers.
After considering comments, and
given the nature of the issues raised by
commenters on the proposal to establish
FIGI, as well as the notable divergence
in commenters’ views, the Agencies are
not establishing FIGI as a joint standard
in this rulemaking. This approach will
provide the Agencies with the flexibility
to consider what further action, if any,
to take regarding FIGI either in a later
joint Agency rulemaking or in each
Agency’s own individual rules (whether
as part of implementing the FDTA or in
other Agency rulemakings). This
approach also will permit the Agencies
to consider the differing views
commenters expressed about the utility,
benefits, and costs of FIGI relative to
other financial instrument identifiers,
including in any future Agency-specific
action in the context of a specific
collection of information. Not
establishing FIGI as a common identifier
in this rulemaking also provides
additional time for the Agencies to
monitor developments with respect to
the use and adoption of FIGI and other
financial instrument identifiers by
market participants.
Certain commenters suggested that
the Agencies consider establishing
financial instrument identifiers other
than FIGI, including CUSIP numbers,
OTC ISIN, and ISO 24165—Digital
Token Identifier (DTI). Some
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dentifiers by
market participants.
Certain commenters suggested that
the Agencies consider establishing
financial instrument identifiers other
than FIGI, including CUSIP numbers,
OTC ISIN, and ISO 24165—Digital
Token Identifier (DTI). Some
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75 See ISO 8601, Date and time format,
International Organization for Standardization,
available at https://www.iso.org/iso-8601-date-and-
time-format.html.
76 In conformity with the other common
identifiers, the Agencies are including the name of
ISO 8601, ‘‘Date and time—Representations for
information interchange’’ in the joint standards.
77 See appendix B, Two-Letter State and
Possession Abbreviations, U.S. Postal Service,
available at https://pe.usps.com/text/pub28/
28apb.htm.
commenters also suggested that the
Agencies consider exploring various
alternative approaches, including, for
example, seeking agreements with
CUSIP Global Services and the
American Bankers Association to aid
more open access to CUSIP numbers/
ISIN for specific use cases or the
creation of a ‘‘CUSIP based FIGI.’’ These
commenters offered various reasons
why these should be included as
financial instrument identifiers, in
particular suggesting they were widely
used or how they met various elements
of the FDTA standards. The Agencies
are not establishing these financial
instrument identifiers at this time
because, as with FIGI, further review
into issues that are beyond the scope of
this rulemaking is required to determine
their appropriateness as a joint
standard, including their utility,
benefits, and costs
ticular suggesting they were widely
used or how they met various elements
of the FDTA standards. The Agencies
are not establishing these financial
instrument identifiers at this time
because, as with FIGI, further review
into issues that are beyond the scope of
this rulemaking is required to determine
their appropriateness as a joint
standard, including their utility,
benefits, and costs. Given the concerns
raised by commenters regarding FIGI,
including commenters questioning
whether any common financial
instrument identifier was necessary, the
Agencies are not establishing FIGI or
any other common financial instrument
identifier as a joint standard. Each
implementing Agency retains the
flexibility to consider whether to utilize
these or other financial instrument
standards as they each implement the
joint standards during their individual
Agency rulemakings. At that time, any
implementing Agency that chooses to
implement a financial instrument
standard can seek public input.
3. Dates
For date fields, the Agencies proposed
to establish the date as defined by ISO
8601 using the Basic format option
(which minimizes the number of
separators).75 For example, the Basic
format would appear as YYYYMMDD
whereas the Extended format appears as
YYYY–MM–DD. In the preamble to the
proposed joint rule, the Agencies
recognized that date and time
information may be displayed on forms,
web pages, user interfaces, and other
media in other formats (e.g., Month,
Day, Year). However, the Agencies
proposed that underlying machine-
readable data should, to the extent
feasible, follow the ISO 8601 format.
The Agencies are establishing ISO 8601
as the date format in the joint standards
but, having considered public
comments, are not establishing the use
of the Basic format option.
The Agencies received several
comments on the proposed date codes
standard. The majority of the
commenters supported the proposal
achine-
readable data should, to the extent
feasible, follow the ISO 8601 format.
The Agencies are establishing ISO 8601
as the date format in the joint standards
but, having considered public
comments, are not establishing the use
of the Basic format option.
The Agencies received several
comments on the proposed date codes
standard. The majority of the
commenters supported the proposal.
One commenter, while generally
supportive of the ISO 8601 standard,
questioned the need for specifying use
of the Basic format option. The
commenter stated that the decision
whether to use the Basic or Extended
format, both of which are within ISO
8601, should be left to each Agency’s
individual discretion. The commenter
stated that derivatives market
participants have widely adopted use of
the ISO 8601 Extended format in
response to guidance issued by
international authorities, including FSB
and the International Organization of
Securities Commissions, that
recommended use of the Extended
format for reporting details of over-the-
counter derivatives transactions to
regulators. The commenter expressed
concern that mandating use of the Basic
format could force entities in the
derivatives market to undertake costly
system changes for no apparent
regulatory benefit, particularly given
one of the Agencies already requires
dates to be reported in Extended ISO
8601 format in accordance with the
guidance issued by international
authorities.
A few commenters opposed the ISO
8601 standard. One commenter
expressed concern about the preamble
language referencing the ‘‘underlying
machine-readable data.’’ The
commenter stated that this might
constitute regulatory overreach if by
‘‘underlying’’ the Agencies meant the
data as stored in internal databases. The
commenter noted that in many cases,
and for various reasons, these databases
might use formats more aligned to rapid
comparison such as the number of
seconds since 01–01–1970
nguage referencing the ‘‘underlying
machine-readable data.’’ The
commenter stated that this might
constitute regulatory overreach if by
‘‘underlying’’ the Agencies meant the
data as stored in internal databases. The
commenter noted that in many cases,
and for various reasons, these databases
might use formats more aligned to rapid
comparison such as the number of
seconds since 01–01–1970. Another
commenter expressed concern about the
potential economic impact on entities
currently using a different standard and
recommended that the Agencies further
analyze such costs before issuing the
final joint rule.
The Agencies agree that there is not
a need to specify the Basic format
option in the joint standards and are
therefore not establishing it as part of
those standards.76 As noted by the
commenter, some Agencies currently
utilize the Extended format and thus it
may be disruptive for those Agencies,
and entities that report information to
those Agencies, to change to the Basic
format. Because it is relatively
straightforward to convert dates
between Basic and Extended formats
given the only difference between the
two is the existence of separators, there
is no need to specify the Basic format
given this potential disruption. The
Agencies believe the primary issue
addressed by this standard is the order
of the date components themselves such
as YYYYMMDD, and varying use of
Basic or Extended date formats will not
significantly impede interoperability.
To address commenters’ other
concerns, the Agencies would also like
to clarify the preamble language in the
proposed joint rule regarding how
underlying machine-readable data is
maintained when displaying date and
time in other formats on forms, web
pages, user interfaces and other media.
This language was in reference to how
the Agencies maintain their own data.
The final joint rule does not impose any
standard on how reporting entities or
other third-parties store data
eamble language in the
proposed joint rule regarding how
underlying machine-readable data is
maintained when displaying date and
time in other formats on forms, web
pages, user interfaces and other media.
This language was in reference to how
the Agencies maintain their own data.
The final joint rule does not impose any
standard on how reporting entities or
other third-parties store data.
The Agencies recognize that any
future adoption of the date codes
standard by the Agencies in their
Agency-specific rulemakings may result
in entities incurring some costs to revise
their existing systems. As discussed, the
decision whether to mandate the use of
any standard established by this final
joint rule is left to the discretion of the
individual Agencies. Accordingly, as
discussed in section I.B above, the
Agencies believe that the costs
associated with adoption of the joint
data standard can only be meaningfully
addressed by each Agency during the
Agency-specific rulemakings or other
Agency action.
4. States, Possessions, or Military
‘‘States’’ of the United States of America
or Geographic Directionals
For identification of a State,
possession, or military ‘‘state’’ of the
United States of America or a
geographic directional, the Agencies are
establishing as proposed the U.S. Postal
Service Abbreviations, as published in
appendix B of Publication 28 ‘‘Postal
Addressing Standards, Mailing
Standards of the United States Postal
Service.’’ 77 For example, the standard
would render ‘‘Alabama’’ as the two-
character abbreviation, ‘‘AL,’’ and calls
for the use of abbreviations for
geographic directionals (e.g., ‘‘N’’ for
‘‘North’’).
The Agencies received several
comments on the proposed standard,
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standard
would render ‘‘Alabama’’ as the two-
character abbreviation, ‘‘AL,’’ and calls
for the use of abbreviations for
geographic directionals (e.g., ‘‘N’’ for
‘‘North’’).
The Agencies received several
comments on the proposed standard,
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
78 See ISO 3166, Country Codes, available at
https://www.iso.org/iso-3166-country-codes.html.
See also Independent States in the World, U.S.
Department of State, available at https://
www.state.gov/independent-states-in-the-world/.
79 One commenter suggested that the standards
should be more specific to avoid ambiguity and
promote interoperability, but did not provide
specific suggestions as to how the Agencies should
amend the proposed standard.
80 Public Law 80–242 (July 25, 1947) requires that
all Federal government agencies use the naming
standards adopted by the GENC. The GENC
standard excludes ISO 3166 codes for entities not
lawfully recognized by U.S. law.
81 See ISO 4217, Currency codes, International
Organization for Standardization, available at
https://www.iso.org/iso-4217-currency-codes.html.
82 One commenter also highlighted some coverage
limitations of ISO 4217, but indicated that these
limitations are not a factor limiting its use in the
joint standards.
83 Section 124(c)(1)(B) of the Financial Stability
Act requires that the joint standards to the extent
practicable ‘‘enable high quality data through
schemas, with accompanying metadata documented
in machine-readable taxonomy or ontology models,
which clearly define the semantic meaning of the
data, as defined by the underlying regulatory
information collection requirements[.]’’
with the majority supporting the
proposal
inancial Stability
Act requires that the joint standards to the extent
practicable ‘‘enable high quality data through
schemas, with accompanying metadata documented
in machine-readable taxonomy or ontology models,
which clearly define the semantic meaning of the
data, as defined by the underlying regulatory
information collection requirements[.]’’
with the majority supporting the
proposal. One commenter noted that
long names, and not abbreviations, are
widely used throughout the derivatives
market and have been incorporated into
industry standards. This commenter
opposed the proposed standard in cases
where long names are currently used for
geographic directionals in over-the-
counter derivatives transactions as it
would require firms to incur the costs of
updating their systems for no apparent
regulatory benefit.
The Agencies have considered the
comments and are establishing the
States and geographical directional
codes standard as proposed.
Identification of a State, possession,
military ‘‘state,’’ or geographic
directional is widely used in collections
that are subject to the FDTA. As
compared to alternative numeric State
codes, the standard established by this
final joint rule is more widely used and
is more conducive to use by both
humans and machines. With regard to
the costs that might be incurred by
regulated entities in complying with the
standard, as discussed in section I.B
above, the Agencies have the ability to
evaluate the appropriateness of
mandating any particularized changes
from current practices as part of their of
the Agency-specific rulemakings or
other Agency action implementing the
joint standards.
5. Countries and Their Subdivisions
For identification of countries, the
Agencies are establishing as proposed
the codes for countries and their
subdivisions, as appropriate, as defined
by the GENC standard. GENC, which
was developed by the Country Codes
Working Group of the Geospatial
Intelligence Standards Working Group,
specifies the U.S
gency action implementing the
joint standards.
5. Countries and Their Subdivisions
For identification of countries, the
Agencies are establishing as proposed
the codes for countries and their
subdivisions, as appropriate, as defined
by the GENC standard. GENC, which
was developed by the Country Codes
Working Group of the Geospatial
Intelligence Standards Working Group,
specifies the U.S. Government profile of
ISO 3166, ‘‘Codes for the Representation
of Names of Countries and their
Subdivisions.’’ 78 For example, the
United States of America would be
rendered in either the two-character
abbreviation ‘‘US’’ or the three-character
abbreviation ‘‘USA.’’ As noted in the
preamble to the proposed joint rule, this
profile addresses requirements unique
to the U.S. Government for: restrictions
in recognition of the national
sovereignty of a country; identification
and recognition of geopolitical entities
not included in ISO 3166; and use of
names of countries and country
subdivisions that have been approved
by the U.S. Board on Geographic Names.
The Agencies received several
comments on the proposed standard.
While many commenters supported the
proposed standard, a few commenters
opposed it.79 Principally, these
commenters were concerned that the
GENC modifications to the ISO 3166
standard would be impractical to use in
the context of derivatives transactions
and would be disruptive to that market
given the broad international adoption
of the unmodified ISO 3166 standard.
Similar to concerns raised in relation to
other standards, these commenters
expressed concern that mandating the
GENC modifications would require
industry to incur the costs of substantial
system builds and adaptations. These
commenters urged the Agencies to
permit use of the ISO 3166 standard
without modification. The commenters
also stated that any change to the
current format of a regulatory report
should be subject to further cost-benefit
analysis
ommenters
expressed concern that mandating the
GENC modifications would require
industry to incur the costs of substantial
system builds and adaptations. These
commenters urged the Agencies to
permit use of the ISO 3166 standard
without modification. The commenters
also stated that any change to the
current format of a regulatory report
should be subject to further cost-benefit
analysis.
The Agencies have considered these
comments but are not revising the
proposed joint rule. The GENC standard
is required to be used among Federal
agencies and other entities in the United
States and helps provide consistency
and interoperability of references to
geopolitical entities.80 The Agencies
recognize that subsequent adoption of
the standard in an Agency-specific
rulemaking could require some entities
to incur additional system costs.
However, the Agencies emphasize that
this final joint rule does not mandate
the use of any specific standard. Rather,
the decision whether to require use of
a standard identified in this final joint
rule is left to each individual Agency in
its Agency-specific rulemakings.
Accordingly, the economic
considerations can only be meaningfully
addressed by each Agency during the
Agency-specific rulemakings or other
Agency action implementing the joint
standards.
6. Currencies
For identification of currencies, the
Agencies are establishing as proposed
the alphabetic currency code as defined
by ISO 4217 Currency Codes.81
Commenters generally expressed
support for the proposed standard.82 As
noted in the preamble to the proposed
joint rule, these internationally
recognized codes are widely used and
incorporated into many other data
standards. This standard helps support
interoperability, enable clarity, and
reduce errors.
D. Data Transmission and Schema and
Taxonomy Format Standards
Standardizing the way in which
information is transmitted to the
Agencies can promote the
interoperability of that information
ed
joint rule, these internationally
recognized codes are widely used and
incorporated into many other data
standards. This standard helps support
interoperability, enable clarity, and
reduce errors.
D. Data Transmission and Schema and
Taxonomy Format Standards
Standardizing the way in which
information is transmitted to the
Agencies can promote the
interoperability of that information. The
formats that the Agencies use to
digitally receive collections of
information are referred to as data
transmission formats.
For certain collections, submitted
information may refer to one or more
schemas, taxonomies, or ontology
models that describe the syntax,
structure, or semantic meaning of the
information. These can be used to
validate and explain the information. A
high-quality machine-readable
description of the syntax and structure
of a data asset allows for automated
verification of the associated data asset.
A high-quality machine-readable
description of semantic meaning of a
data asset ensures that the specific
meaning remains clear as the data asset
is transmitted to multiple parties.83 Not
all Agency collections of information
have a schema and taxonomy associated
with them, as a schema and taxonomy
may not be appropriate in all
circumstances. Further, a schema and
taxonomy would not be required for all
collections of information subject to the
FDTA. The formats used to develop and
publish schemas and taxonomies are
referred to as schema and taxonomy
formats.
Rather than proposing a specific data
transmission or schema and taxonomy
format, the proposed joint rule provided
that, to the extent practicable, a data
transmission or schema and taxonomy
format should have the following
properties derived from the
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proposing a specific data
transmission or schema and taxonomy
format, the proposed joint rule provided
that, to the extent practicable, a data
transmission or schema and taxonomy
format should have the following
properties derived from the
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
84 For example, the Agencies stated that HTML
may satisfy the standard if the data within the
HTML document conforms to a schema (e.g., Inline
XBRL), and PDF may satisfy the standard if the data
within the PDF conforms to specification ‘‘A’’ (PDF/
A) that uses advanced features for tagging fields
with a reference schema and taxonomy and
provides necessary metadata that allows for
automated data extraction. However, the Agencies
further stated that HTML and PDF documents
whose data does not conform to any such schema
and taxonomy would not be considered machine-
readable as that term is defined in the FDTA
because the data contained in such HTML and PDF
documents cannot be easily processed by a
computer without human intervention while
ensuring no semantic meaning is lost.
85 Section 124(c)(2)(B) of the Financial Stability
Act.
requirements listed in section
124(c)(1)(B) of the Financial Stability
Act:
D Render data fully searchable and
machine-readable;
D Enable high quality data through
schemas, with accompanying metadata
documented in machine-readable
taxonomy or ontology models, which
clearly define the semantic meaning of
the data, as defined by the underlying
regulatory information collection
requirements, as appropriate;
D Ensure that a data element or data
asset that exists to satisfy an underlying
regulatory information collection
requirement be consistently identified
as such in associated machine-readable
metadata; and
D Be nonproprietary or available
under an open license
e the semantic meaning of
the data, as defined by the underlying
regulatory information collection
requirements, as appropriate;
D Ensure that a data element or data
asset that exists to satisfy an underlying
regulatory information collection
requirement be consistently identified
as such in associated machine-readable
metadata; and
D Be nonproprietary or available
under an open license.
One of these properties is that, to the
extent practicable, a data element or
data asset that exists to satisfy an
underlying regulatory information
collection requirement must be
consistently identified as such in
associated machine-readable metadata.
This property is set forth in section
124(c)(1)(B)(iii) of the Financial
Stability Act. This means that, to the
extent practicable and where collection
of information is pursuant to regulatory
requirements, a schema and taxonomy
should include machine-readable
metadata to track the applicable
regulatory requirements. Applicable
regulatory requirements should be
easily identifiable for data assets that are
collections of information subject to the
PRA. To the extent practicable,
Agencies may also identify applicable
regulatory requirements on a data-
element level.
The proposed joint rule stated that
any data transmission or schema and
taxonomy format that, to the extent
practicable, has these properties would
be consistent with this proposed joint
standard
fiable for data assets that are
collections of information subject to the
PRA. To the extent practicable,
Agencies may also identify applicable
regulatory requirements on a data-
element level.
The proposed joint rule stated that
any data transmission or schema and
taxonomy format that, to the extent
practicable, has these properties would
be consistent with this proposed joint
standard. The Notice of Proposed
Rulemaking identified a number of
existing data transmission formats that
can be used in a method that satisfies
these requirements, including Comma
Separated Values (CSV) or other
delimiter-separated files, eXtensible
Markup Language (XML), Java Script
Object Notation (JSON), and, to the
extent it is used with a schema or a
standard that permits it to be machine-
readable, HyperText Markup Language
(HTML) and Portable Document Format
(PDF).84 The Agencies also stated that
XML Schema Definition (XSD),
eXtensible Business Reporting Language
(XBRL) Taxonomy, and JSON Schema
are currently available schema and
taxonomy formats that have the
properties called for in the proposed
joint data standard. As a result, the
proposed joint standard referred to a list
of properties rather than any specific
data transmission or schema and
taxonomy formats.
Some commenters expressed support
for establishing data transmission or
schema and taxonomy formats
standards in this manner. These
commenters stated that they believed
that this approach would provide the
most flexibility for new formats that
develop over time and keep the joint
standard technology neutral. They also
highlighted the ability of the proposed
principles-based data standard to meet
current industry practices and believed
that they support the aims of the FDTA.
Instead of the proposed properties-
based joint standard, some commenters
recommended the establishment of
specific data transmission or schema
and taxonomy formats
ver time and keep the joint
standard technology neutral. They also
highlighted the ability of the proposed
principles-based data standard to meet
current industry practices and believed
that they support the aims of the FDTA.
Instead of the proposed properties-
based joint standard, some commenters
recommended the establishment of
specific data transmission or schema
and taxonomy formats. These
commenters raised concerns that a
principles-based approach would have a
negative impact on the interoperability
of the joint standards. These
commenters recommended a number of
particular standards, including both
those discussed in the Notice of
Proposed Rulemaking like CSV, JSON,
XML, and XBRL, as well as others like
the Algorithmic Contract Types Unified
Standards, the Financial Industry
Business Ontology, Universal Financial
Industry Messaging Scheme ISO 20022,
Common Domain Model (data
standards), Financial Information
eXchange Markup Language, FIX-
Orchestra, FIX-TagValue encoding,
Financial products Markup Language,
and Simple Binary Encoding. One of
these commenters suggested a number
of other standards, including Multiple
Vocabulary Facility; Languages
Countries and Codes; Commons
Ontology Library; Pedigree and
Provenance Model and Notation; and
Distributed Ontology, Model and
Specification Language, although the
commenter noted that these standards
are not tailored to financial data. This
commenter also recommended several
other prospective standards that are
currently under development,
specifically the Data Products Ontology,
Standard Business Report Model, and
Statistical Metadata Interoperability.
The Agencies considered these
comments recommending specific data
transmission or schema and taxonomy
formats and determined that
establishing a joint standard that refers
to a list of properties rather than any
specific data transmission or schema
and taxonomy formats would be
appropriate for several reasons
gy,
Standard Business Report Model, and
Statistical Metadata Interoperability.
The Agencies considered these
comments recommending specific data
transmission or schema and taxonomy
formats and determined that
establishing a joint standard that refers
to a list of properties rather than any
specific data transmission or schema
and taxonomy formats would be
appropriate for several reasons. While
the Agencies agree that interoperability
is an important consideration, given that
the FDTA specifically directs the
Agencies to ‘‘seek to promote
interoperability of financial regulatory
data across members of the FSOC’’
when establishing the joint standards,85
the interoperability benefits of greater
specificity in the joint standards must
also be balanced against the practicality
of those standards. The principles-based
approach has significant benefits that
were recognized by other commenters.
For example, this approach gives the
Agencies the flexibility to adopt
specific, fit-to-purpose formats and also
adopt new formats as they are
developed, provided that the new
formats have the listed properties.
Further, because the list of properties is
derived from the requirements listed in
section 124(c)(1)(B) of the Financial
Stability Act, any data transmission or
schema and taxonomy format data
standards with these properties would
satisfy the FDTA’s related requirements
and would likely include many of the
formats identified by commenters and
acknowledged by the Agencies in the
preamble to the proposed joint standard.
Further, while one commenter
disagreed, the Agencies nonetheless
believe that data transmission or schema
and taxonomy formats that have these
properties are likely to be interoperable
with each other
atisfy the FDTA’s related requirements
and would likely include many of the
formats identified by commenters and
acknowledged by the Agencies in the
preamble to the proposed joint standard.
Further, while one commenter
disagreed, the Agencies nonetheless
believe that data transmission or schema
and taxonomy formats that have these
properties are likely to be interoperable
with each other. For example, as
discussed above, to meet the joint
standard an Agency must determine that
a data element or data asset that exists
to satisfy an underlying regulatory
information collection requirement be
consistently identified as such in
associated machine-readable metadata
to the extent practicable. This principle
could lead different Agencies to
determine the same data transmission or
schema and taxonomy standard is
appropriate when implementing the
joint standards. Alternatively, different
Agencies could determine, as one
commenter suggested, different
standards that are interoperable with
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
each other are appropriate when
implementing the joint standards.
Some commenters stated that it would
not be appropriate to establish certain
formats expressly identified by the
Agencies in the preamble to the
proposed joint standard. One
commenter suggested that PDF, and
PDF/A do not meet the requirements of
the FDTA. Other commenters asserted
that JSON, XML, and CSV do not meet
the requirements of the FDTA unless
accompanied by a complete taxonomy.
As discussed above, the Agencies
contemplated that certain formats may
only meet the requirements of the FDTA
in certain circumstances
le to the
proposed joint standard. One
commenter suggested that PDF, and
PDF/A do not meet the requirements of
the FDTA. Other commenters asserted
that JSON, XML, and CSV do not meet
the requirements of the FDTA unless
accompanied by a complete taxonomy.
As discussed above, the Agencies
contemplated that certain formats may
only meet the requirements of the FDTA
in certain circumstances. The preamble
to the proposed joint rule acknowledged
that there are currently various data
transmission formats that generally have
properties that would be consistent with
the final joint standard. For example,
there are methods of using JSON, XML,
PDF/A, and CSV in a manner that
satisfies these joint standards.
Other commenters stated that
individual collections of information
that may use specific data transmission
or schema and taxonomy formats should
not impose new burdens or unnecessary
costs. One commenter requested clarity
regarding whether the proposed
properties-based approach for data
transmission or schema and taxonomy
formats should, to the extent
practicable, be applicable to reporting
for every collection of information.
Another commenter requested that all
collections of information required by
the Agencies include a supporting
schema or taxonomy. One commenter
specifically requested that the Agencies
refrain from altering, as applicable to
credit unions, the current data standards
that apply to the 5300 Call Report or
4501A Profile. One commenter
requested clarification whether
Agencies’ filing systems meet the
proposed joint rule’s data transmission
principles, or whether any of these
reporting channels will need to be
updated once the joint data standards
are finalized. As discussed in section I.B
above, the Agencies emphasize that this
final joint rule does not mandate the use
of any specific standard or impose any
immediate changes to collections of
information
cies’ filing systems meet the
proposed joint rule’s data transmission
principles, or whether any of these
reporting channels will need to be
updated once the joint data standards
are finalized. As discussed in section I.B
above, the Agencies emphasize that this
final joint rule does not mandate the use
of any specific standard or impose any
immediate changes to collections of
information. Rather, the application of
the joint standards to specific
collections of information, if determined
by an Agency to be appropriate to a
specific collection of information,
would take effect through adoption by
an Agency of an Agency-specific
rulemaking or other action.
Another commenter recommended
the replacement of the terms ‘‘data
transmission format’’ and ‘‘schema and
taxonomy format’’ with the Open
Systems Interconnection (OSI) Model
(ISO/International Electrotechnical
Commission (IEC) 7498), a seven-layer
model that describes messaging systems.
The Agencies have taken the comments
under consideration, and determined
that the terms ‘‘data transmission
format’’ and ‘‘schema and taxonomy
format’’ are more meaningful to a
broader audience than using ‘‘OSI Layer
6,’’ which requires familiarity with the
OSI Model to understand.
One commenter requested that the
Agencies move from report-based
information collections to a data-centric
methodology. The joint rulemaking is
meant to establish joint data standards
for collections of information, but is not
meant to effectuate a complete paradigm
shift in how individual Agencies collect
information. Therefore, the Agencies
believe the commenter’s request is
beyond the scope of the final joint rule.
Several commenters expressed
support for the inclusion of the language
‘‘to the extent practicable’’ in the data
transmission and schema and taxonomy
format data standards. This is because of
the broad market coverage of the formats
and given the four properties may not be
applicable to every collection of
information currently
enter’s request is
beyond the scope of the final joint rule.
Several commenters expressed
support for the inclusion of the language
‘‘to the extent practicable’’ in the data
transmission and schema and taxonomy
format data standards. This is because of
the broad market coverage of the formats
and given the four properties may not be
applicable to every collection of
information currently. One commenter
recommended that the final joint rule
remove this language in order to prevent
the Agencies from selectively choosing
which data collections will include data
transmission and schema and taxonomy
format standards, which could limit the
benefits of data standardization. The
Agencies have considered these
comments and determined to include
the language ‘‘to the extent practicable’’
in the data transmission and schema
and taxonomy format data standards as
proposed, given the FDTA’s
requirement that the standards
ultimately adopted by the Agencies be
compatible with the joint standards to
the extent feasible and have the
characteristics embodied by the four
properties called for in the established
data transmission and schema and
taxonomy standard to the extent
practicable.
One commenter was supportive of not
establishing specific taxonomy
standards, but requested further analysis
on structured data formats and various
format types discussed in the proposed
joint rule. As discussed in section I.B
above, the Agencies emphasize that this
final joint rule does not mandate the use
of any specific standard or impose any
immediate changes to collections of
information. Rather, the application of
the joint standards to specific
collections of information would take
effect through adoption by an Agency of
an Agency-specific rulemaking or other
action. To the extent that an individual
Agency proposes to adopt a particular
data transmission and schema and
taxonomy format, that Agency may
conduct further analysis on particular
structured data formats and format
types
application of
the joint standards to specific
collections of information would take
effect through adoption by an Agency of
an Agency-specific rulemaking or other
action. To the extent that an individual
Agency proposes to adopt a particular
data transmission and schema and
taxonomy format, that Agency may
conduct further analysis on particular
structured data formats and format
types.
Another commenter recommended
that the Agencies limit taxonomy styles
and provide recommendations on how
to harmonize taxonomies, led by the
Agencies’ individual Offices of the Chief
Data Officer in collaboration to identify
consistent data fields and tags across
Agencies. This comment is outside the
scope of the final joint rule. To the
extent that an individual Agency
proposes to adopt a particular data
transmission and schema and taxonomy
format that implicates the concerns
raised in its Agency-specific
rulemaking, it may conduct further
analysis on particular structured data
formats and format types.
One commenter expressed concern
that individual Agency rules may
impose specific taxonomies for
individual information collections and
requested that the final joint rule
provide clarification to avoid the
establishment of complex overlapping
taxonomies for future Agency-specific
rulemakings. The purpose of the four
properties called for in the data
transmission and schema and taxonomy
standard is to help coordinate those
standards among the Agencies in a way
that is consistent with the requirements
of the FDTA. When implementing the
joint standard, the Agencies are required
to consider the applicability, feasibility,
practicability, scaling, minimization of
disruption to affected persons, and
tailoring, as specified in the FDTA. This
provides a framework for each Agency,
in its implementation of the joint
standards, to consider appropriate
taxonomies, if any, and to coordinate
with the other Agencies as appropriate
on these determinations.
E
s are required
to consider the applicability, feasibility,
practicability, scaling, minimization of
disruption to affected persons, and
tailoring, as specified in the FDTA. This
provides a framework for each Agency,
in its implementation of the joint
standards, to consider appropriate
taxonomies, if any, and to coordinate
with the other Agencies as appropriate
on these determinations.
E. Accounting and Reporting
Taxonomies and Census Tracts
In the proposed joint rule, the
Agencies invited comment on whether
to establish a joint standard for
accounting and reporting taxonomies
and whether to establish a standard for
census tracts, specifically identifying
the 11-digit format census tract code
defined by the U.S. Census Bureau,
which includes a 5-digit Federal
Information Processing Standards
country code prefix followed by a 6-
digit tract code with no decimals and
allows for leading or trailing zeros as
applicable. The Agencies, however, did
not propose either standard and, after
considering the comments, are not
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Federal Register / Vol. 91, No. 121 / Thursday, June 25, 2026 / Rules and Regulations
86 Some municipal issuers use non-GASB GAAP,
non-FASB GAAP, or cash basis accounting.
establishing either one in the final joint
standards.
As discussed in the proposed joint
rule, the FDTA does not explicitly
require the establishment of specific
taxonomies as joint standards. Further,
the Agencies stated that it is not clear
whether the establishment of specific
taxonomies is necessary to enable high
quality data, given that the use of any
taxonomy would further this objective
shing either one in the final joint
standards.
As discussed in the proposed joint
rule, the FDTA does not explicitly
require the establishment of specific
taxonomies as joint standards. Further,
the Agencies stated that it is not clear
whether the establishment of specific
taxonomies is necessary to enable high
quality data, given that the use of any
taxonomy would further this objective.
Nonetheless, the Agencies requested
comment on the following two options:
(option 1) whether to establish a joint
standard for taxonomies based on
certain properties and, if so, the
properties that should be set forth in the
joint standard; or (option 2) whether to
establish specific taxonomies and, if so,
the taxonomies that should be set forth
in the joint standard (such as the
Federal Financial Institutions
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