Regulations

Form 13F is the reporting form filed by institutional investment managers pursuant to Section 13(f) of the Securities Exchange Act of 1934.

Congress passed Section 13(f) of the Securities Exchange Act in 1975 in order to increase the public availability of information regarding the securities holdings of institutional investors.

FIGI is an option for similar reporting in Australia, where an alpha-numeric identifier can be used for underlier ID (other).

https://www.financialresearch.gov/data/collections/files/nccbr-reporting-instructions.pdf (see page 7)

FIGI is a supported identifier for insurance company financial instrument exposure reporting in EU Solvency II legislation.

A reporting person must provide the Council on Uniform Securities Identification Procedures (“CUSIP”) number for the security pursuant to Item 1(b), unless the CUSIP is not available through reasonably practicable means, e.g., in the case of certain securities of foreign issuers. If the CUSIP is not available through reasonably practicable means, the reporting person must provide the International Securities Identification Number (“ISIN”) pursuant to Item 1(c), unless the ISIN is not available through reasonably practicable means. A reporting person may choose to report the global share class Financial Instrument Global Identifier (“FIGI”) for the security pursuant to Item 1(d).

The global share class Financial Instrument Global Identifier (“FIGI”) for the security (optional)

https://www.hkma.gov.hk/media/eng/doc/key-information/press-release/2024/20240926e3a1.pdf (Please see details in page 115/166)

HKMA and SFC conclude on further proposals to enhance Hong Kongs OTC derivatives reporting regime in Sept 2024. In the consultation conclusion, the 2 key regulators in HK mentioned there is no restriction to use FIGI in the OTC Derivatives Underlier ID (OTHER) field.

Question 40 continues to require advisers to report for each reference asset the CUSIP, if any, and at least one of the following identifiers: ISIN, ticker, if ISIN is not available, or other unique identifier, if ISIN and ticker are not available. Advisers may, on an optional basis, report for each reference asset the FIGI.

The Commission will adopt this proposal and "FIGI" has been added to the Part 17 Guidebook as an alternative identifier for underlying contracts, alongside CUSIP, SEDOL, QUIK, ISIN, and Bloomberg Symbol. FIGI is a free, open source identifier available to all market participants and accepted as a U.S. national standard by the Accredited Standards Committee X9 Inc.121 Allowing FIGI as an alternative underlier identifier is consistent with its adoption as an alternative identifier for other reporting schemes. For example, FIGI is allowed as an alternative identifier in Form 13F reporting required by the Securities and Exchange Commission.122 FIGI is also accepted by the Derivatives Services Bureau as an alternative underlier identifier for the creation of a Unique Product Identifier ("UPI") for swap data repository reporting purposes. The Commission supports providing reporting firms the option to choose among financial identifiers and believes it appropriate to allow FIGI as a value to be reported for the underlying contract data in the Part 17 Guidebook.

A covered person shall provide the following information, if applicable, to an RNSA, by the end of the day on which a covered securities loan is affected.

The final rule permits a covered person to determine which identifier to report, or if it prefers, it may also report multiple identifiers, but one identifier is required to be reported. Further, the final rule also permits the covered person to report a different identifier than the ticker symbol, ISIN, CUSIP, or FIGI.

The Commission will also adopt, as proposed, the requirement that Managers report in Column 6 of each of the Form SHO Information Tables the FIGI of the equity security for which information is being reported, if a FIGI has been assigned. Like CUSIP, FIGI provides a methodology for identifying securities, and reporting a FIGI, if assigned, will provide additional identifying information that will provide additional clarity, not confusion, to market participants and the public. Unlike CUSIPs, however, FIGIs are provided for free.

FIGI, if assigned, is to be reported on two tables: one for monthly gross short position and the other for daily activity affecting gross short position. FIGI has its own column on the Reg SHO Information Tables alongside CUSIP. The SEC acknowledged that FIGIs are widely used in the financial markets and that the Commission recently added their use on Form 13F filings. The SEC further noted that FIGIs are automatically assigned and are retrievable and redistributable without licensing restricting at no cost, even though there may be a one-time cost incurred to implement first-time use. ("Like CUSIP, FIGI provides a methodology for identifying securities, and reporting a FIGI, if assigned, will provide additional identifying information that will provide additional clarity, not confusion, to market participants and the public. Unlike CUSIPs, however, FIGIs are provided for free.")

https://www.mas.gov.sg/-/media/MAS-Media-Library/publications/consultations/ID/2022/Notice-122-Consultation-Response-Paper.pdf (Please see details in page 9/71)

Monetary Authority of Singapore Proposed Changes to Notice 122 on Assets and Liabilities Exposures for Insurers and its Implementation in May 2022. MAS allows users to submit unique identifiers including SEDOL, CUSIP, Short Code and FIGI.