Extension Request to the SEC on the Financial Data Transparency Act

Dear Ms. Countryman:

The American Bankers Association ("ABA") appreciates the opportunity to comment on the proposal by nine federal agencies ("Agencies") to establish joint data standards for collections of information reported to the Agencies under Section 124 of the Financial Stability Act of 2010, which has been added pursuant to Section 5811 of the Financial Data Transparency Act of 2022 ("FDTA"). We respectfully urge the Agencies to reconsider the proposed establishment of Bloomberg LP’s Financial Instrument Global Identifier (“FIGI”) as the common financial instruments identifier and to issue a revised Notice of Proposed Rulemaking that complies with the Administrative Procedure Act (“APA”). If the Agencies nonetheless choose to proceed with the current proposal, we respectfully request a 60-day extension of the 60-day comment period in order to be provided with a reasonable and meaningful opportunity to comment on the Proposed Rule’s establishment of FIGI as the common financial instruments identifier.

The Proposed Rule declines to consider the globally relied-upon, fungible Committee on Uniform Security Identification Procedures ("CUSIP") and the closely related International Securities Identification Number ("ISIN") financial instrument identification systems, although they have been and continue to be the standards for uniquely identifying financial instruments across many functions, including financial reporting. The ABA comments as owner of the CUSIP financial instrument identification system.

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