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David Michehl Subject MEMORANDUM To: File No. S7-26-15 From: David Michehl Subject: Summary of meeting with representatives from SWIFT Date: January 28, 2016 On January 28, 2016, representatives from the Securities and Exchange Commission’s Division of Trading and Markets (Michael Gaw, Tom Eady, Yvonne Fraticelli, David Michehl, Kathleen Gross, Sarah Albertson, and Justin Pica) and Division of Economic and Risk Analysis (Narahari Phatak, Burt Porter, Walter Hamscher, Hermine Wong, Yee Loon, Mike Willis) met with Paul Janssens (SWIFT). The SWIFT representative discussed issues relating to the use of ISO 20022. In addition, Mr. Janssens provided the staff with an information paper related to ISO 20022. Information paper Standards – A Value Proposition for Regulators Contents About Standards .....................................................................................................3 About SWIFT & Standards .....................................................................................4 Standards & Regulation .........................................................................................6 About ISO 20022 .....................................................................................................8 ISO 20022 & Regional/Global Adoption ................................................................9 Conclusion ............................................................................................................11 3 Standards – A Value Proposition for Regulators About Standards Norms, models, rules, measures, Rather less obvious are data or semantic Financial messaging standards sit at the systems, principles, prescriptions or standards, which can help consumers, heart of virtually all economic activity, standards: at the heart of society itself businesses and public authorities to from executing the smallest retail you will always find a shared set of understand and engage with a far wider transactions to managing massive global standards by which it lives, and through range of information, products and institutional businesses; they play a key which it interacts with the world around it. counterparts than ever before. role in enabling modern society to function Societies use standards to define objects effectively. Data standards principally define the and elements and how to perform certain meaning and format of data exchanged. Nowhere is the cause of standards in key tasks. Without standards, processes Semantic standards go a step further, financial messaging championed more become unreliable, outcomes uncertain; to describe the meaning of business enthusiastically than at SWIFT. Since trade is impeded, and consumer interests concepts and their relationships in a its genesis in the 1970s, SWIFT has are compromised. Not only do standards way that makes them understandable, worked at removing ambiguity and define what is and what isn’t acceptable, both by humans and to some extent incompatibility in how banks and financial but they also give the members of society machines, thereby aiding automation and institutions interact with each other, while a shared frame of reference by which interoperability. At their best, semantic simultaneously championing security and they can understand each other and standards can act as a model of the higher levels of automation. can consume each other’s products and business, allowing the user to map services. everything out and gain greater insights Some of the most notable “standard” into how processes and actions should successes are visible across the world be organised. “Mandating the use of and evident in everyday life – the bar Common data exchange standards ISO 20022 will enable code, or the shipping container; the light have no competitive advantage for any greater automation and bulb fitting or the screw thread. one business or organisation, but can straight-through processing offer tremendous value to everyone in a given industry, its end consumers and (STP), and a consistent “Decades ago, data were not its supervisors. By using a common set messaging standard as central to the world of of data exchange standards, resources will help reduce data can be focused where value is best financial services businesses created — by addressing business and processing risks. For high- as they are today. We now operational issues — instead of wasting value transactions, errors live in a world that is data- valuable time and incurring costs to reformat and interpret data again and can result in significant driven as never before. As again. financial losses. ISO 20022 data become increasingly Standardisation in the world of finance is aligns well with our future important, momentum less immediately evident in everyday life developments and is a tool continues to build to find than the technical standardisation such as Internet Protocol (IP), that we may be to help us future-proof ways to make our data used to, but it is just as important. With our messaging, providing better— and that’s where the growth in financial internationalisation a consistent data structure standards play a valuable and the explosion in data-driven financial activities, the importance of across all our services and role.” standardisation has recently come to the to all our different customer Linda Powell, Chief Data Officer, Office of Financial fore in a number of areas – most notably segments.” Research, U.S. Department of the Treasury, GS1 in financial communication or messaging Global Forum 2014, Brussels, Belgium, 18 February schemes, which are the focus of this Mr Lai Kok Leong, Vice President of Post Trade 2014. Services at Singapore Stock Exchange (SGX). paper. 4 Standards – A Value Proposition for Regulators The key components of a data standard are data element names, definitions, and “Taxonomies sound boring but are actually really important. formatting rules. Data standards often They involve things like naming conventions and data include information describing procedures, implementation guidelines, and usage ordering: do you enter month-day-year like we do in the requirements. Additionally, standards may U.S., day-month-year as they do in Europe, or year-month- specify data transfer protocols, or other day as they do in Asia? Getting those kinds of simple things information that facilitates and promotes widespread use. right can be the difference between data that is unreliable, and data that can identify a hidden financial vulnerability.” Benefits of standards Commissioner Kara M. Stein, International Cooperation in a New Data-Driven World, Brooklyn Law School, International Business Law Breakfast Roundtable, 26 March 2015. — Improve data quality — Increase data compatibility — Lower costs — Reduce operational risk — Eliminate inefficiencies — Facilitate data collection and data analysis — Create new business opportunities About SWIFT & Standards SWIFT plays an important role in be exchanged, they also specify the order community to specify and publish Market standardisation, notably by creating and in which messages should be sent and Practice - rules and best-practice advice maintaining financial messaging standards received. on how standards should be deployed and reference data standards. Use of to meet particular business needs or to SWIFT Standards acts as Registration standardised messages and reference comply with regulation. Authority (RA) for several standards data ensures that data exchanged that define universal codes for common The SWIFT Standards group maintains between institutions is unambiguous data items, or reference data. RAs are several important message standards. and machine friendly, enabling efficient appointed by the International Organisation automation and so reducing industry The SWIFT MT standard, for instance, for Standardisation (ISO) to ensure the costs and risk. is used for international payments, cash integrity of the reference data defined by management, trade finance and treasury Financial institutions send structured ISO standards, and to publish the data business. Working with the SWIFT electronic messages to one another to in an accessible form for the benefit of community, SWIFT Standards operates perform common business processes, the user community. Examples of such the annual maintenance process for MT, such as making payments or confirming standards include the ISO 9362 Business which ensures that the standard evolves trades. In its role as a financial messaging Identifier Code (BIC - commonly referred to meet changing market needs. standardiser, SWIFT’s Standards group to as the “SWIFT” code), which is used works with the financial community to to identify parties, and the ISO 10383 SWIFT Standards, under contract to define standards for these messages. Market Identifier Code (MIC), which is used ISO, also maintains two open messaging to identify exchanges, trading platforms, standards: ISO 15022, which is used for These standards specify the data regulated or non-regulated markets and securities settlement and asset servicing, elements that can be included in the trade reporting facilities. and ISO 20022, which is scoped to all messages, document the meaning financial industry processes. The role of and format of those data elements and SWIFT Standards also contributes to the ISO 20022 is twofold: it is a methodology specify which of the data elements are formalisation and implementation of other for creating financial messaging mandatory, which are optional, and which reference data standards, notably the ISO standards, and it is a related
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