When we run our Kaizen quality assurance tests on client data, one of the errors we invariably find relates to personal identifiers. These identifiers are potentially needed for:
- Buyer/Seller identifiers
- Buyer/Seller decision maker identifiers
- Investment decision within firm
- Execution within firm
The competent authorities aren’t going to take kindly to errors in these codes as they are absolutely vital to the detection and prosecution of market abuse. For example, if there was a “Dr Evil” insider dealing through multiple accounts at multiple firms, the regulators could only understand his overall trading position if all the firms used the same, correct, code to identify him.
The first golden rule for personal identifiers is that they all start with the ISO two character country code of the individual’s nationality (e.g. ‘GB’, ‘US’, ‘FR’ etc.) followed by the national identifier relevant to that country.
National identifier taxonomies
A list of the national identifier taxonomies can be found in the RTS 22 Annex. For some countries, there is a single taxonomy; for example,for German nationals, only the ‘CONCAT’ can be used. For other countries, there are up to three taxonomies. This leads me to the second golden rule: you can only use the ’Priority 2’ taxonomy if the ‘Priority 1’ taxonomy is not applicable to that individual. For example, the ‘Priority 1’ taxonomy for UK individuals is the National Insurance Number (NINO) and priority 2 is ‘CONCAT’. So if you are identifying a British person, you should only use a ‘CONCAT’ if that person does not have a NINO. Be very careful with this – every British person over the age of 16 will have a NINO, so you should not be identifying any British person over the age of 16 with a CONCAT code.
What is ‘CONCAT’?
‘CONCAT’ is the concatenation of the following four elements:
- 2 character ISO country code (as for all personal identifiers)
- Birth date – in the format YYYYMMDD
- First five characters of first name (right pad with hashes if less than 5 characters)
- First five characters of surname (removing prefixes and right pad with hashes)
- For the name elements, there is a conversion/removal of diacritic characters, apostrophes, hyphens, spaces etc using the transliteration table in ESMA’s Guidelines
- Prefixes to surnames must be removed unless they are ‘attached’
e.g. ‘Von der Leyen’ is ‘LEYEN’; McNeil is ‘MCNEI’ (rather than ‘NEIL#’)
- The individual’s full name should form the basis of the CONCAT – incorrect abbreviations or nicknames must not be used (e.g. ‘JAMES’ rather than ‘JIM##’)
- Titles (e.g. ‘Prof’, ‘Dame’ etc) should be removed
- All UPPER CASE
So, for example, the CONCAT code for that well known French insider dealer Pepé Le Pew, born 4 July 1945, would be: FR19450704PEPE#PEW## (of course, we would need his passport to check that Pepé was his real first name).
What about joint nationals?
Yes, they are very annoying. Especially those Brits who have found an Irish grandmother and now keep going on about the craic and how they’ve got the best passport in the world. Anyway, the rules to determine which national taxonomy to use are as follows:
- If both countries are within the EEA, use the country code of the first nationality when sorted alphabetically by its ISO 3166-1 alpha-2 code
- If one country is within the EEA and one outside, use the EEA code
- If both countries are outside the EEA, use the country whose ISO 3166 code is first when sorted alphabetically
So if it’s joint German and French – use the German taxonomy as ‘DE’ comes before ‘FR’.
For joint Swiss and French – use French taxonomy even though ‘CH’ comes before ‘FR’ (as Switzerland is outside the EEA).
Until further notice, we are pretending Britain is still part of the EEA for the joint nationality rules (!).
One final trap – the code type
Because these are XML fields, you need to identify the ‘code type’. This might vary from ARM to ARM, but the standard code types are as follows:
‘CCPT’ – if you’re using the passport
‘CONCAT’ – if it is a CONCAT code
‘NIDN’ – for any other national identifier.
Where to go to for help
Well, us of course. Firstly, if you are unsure about any of the reporting standards, or just need a refresher, we would heartily recommend our core training course delivered by yours truly which will help ensure you are interpreting the MiFIR transaction reporting details correctly (we also cover EMIR and SFTR too).
If you have any doubt about whether you are reporting correctly, this is why we here at Kaizen exist. You need to have total confidence that your reporting is complete and accurate. (It’s a little like the dentist, the longer you let a problem persist, the more painful it will be when it comes to the remediation.) Please contact us for further details on our quality assurance, reconciliation, governance and training services.
You can discuss personal identifiers further over on our Kaizen LinkedIn page…
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