Emma Kalliomaki is Managing Director of the Association of National Numbering Agencies (ANNA), a global membership body who fosters the implementation and adoption of international standards in the financial services industry. Emma is also Managing Director of the Derivatives Service Bureau (DSB), an organisation founded by ANNA and now working in collaboration with the industry for provision of data standards for identification of Over the Counter (OTC) derivatives. While Emma has been working as MD, the DSB has been designated by the Financial Stability Board as the sole service provider for the future UPI system supporting the DSB to deliver an OTC derivatives identification framework. Emma has over a decade of experience in financial reference data, standards and regulation and previously worked as head of the London Stock Exchange’s SEDOL Masterfile.
Malavika Solanki is part of the Management Team at the Derivatives Service Bureau (DSB). Malavika has worked in the OTC derivatives market for over 20 years, is part of the team that oversees the DSB and was previously responsible for the business development at LCH.Clearnet. Malavika’s experience lies predominantly in launching and scaling global Fintech and Regtech ventures, with a focus on stakeholder engagement and proposition development. Malavika is a graduate of London Business School’s Executive MBA programme, enjoys mentoring high-growth, fintech teams and was recently voted Data Management Vendor Professional of the Year.
Julia: Hello. My name is Julia Streets and welcome to the podcast StreetsTalksTo. In each episode, I interview leaders from some of the most influential firms, bodies and initiatives in the financial services industry.
As every leader will testify, one of the critical factors of success lies in the strength of the team. On each episode, we invite them to bring along a colleague and together we look at what’s at the very forefront of innovation and change. We’ll be thinking about the challenges facing their clients and the industry at large and uncovering the opportunities that exist both today and as we look ahead, particularly as we all navigate these extraordinary times.
We hope you enjoy the series, which you can find on all good podcast channels, and all the episodes are listed on our website, streetsconsulting.com. You could find the episodes using #streetstalksto. Thank you, as always, for listening.
Welcome to StreetsTalksTo: ANNA and DSB, or to you and me, the Association of National Numbering Agencies and the Derivatives Service Bureau. Today I’m delighted to be joined by Emma Kalliomaki, Managing Director of ANNA and the DSB, and Malavika Solanki member of the Management Team at the DSB.
Emma: Hi, thanks for having me. It’s great to be here.
Malavika: Likewise, thank you for having me.
Julia: Let me tell you a little bit about ANNA and DSB. The Association of National Numbering Agencies, or ANNA, is a global member association that seeks to foster standardisation within the financial industry by upholding the international organisation for standardisation principles, also known as ISO.
It’s all about promoting and acting as a registration authority for many reference data codes for financial instruments known to you and me as ISINs, FISNs, and CFI identifier codes. At the very heart of ANNA is the fact that it’s a member national numbering agency. Each member is responsible for the ISINs, FISNs, and CFI assignments and maintenance, acts as a central point for knowledge in their jurisdictions around the world, and are therefore able to assist their local financial communities and also help elevate any local challenges or concerns onto an international level.
Once each of the national numbering agencies have assigned an identifier and also all the associated data around that, ANNA works to consolidate all of this via a centralised depository, the ANNA Service Bureau. It’s all about maintaining data quality and building global operability.
That’s ANNA. If you think about ANNA, the DSB, or the Derivatives Service Bureau, is part of that, was founded by ANNA as a fully automated global generator of ISINs and also CFIs and Financial Instrument Short names or FISNs, but specifically for over the counter OTC derivatives.
I’m delighted today to be joined by Emma Kalliomaki. She’s the Managing Director of ANNA and the DSB, who brings over a decade of experience in financial reference data, standards and regulation, and previously worked as Head of the London Stock Exchange’s SEDOL Master File.
Today Emma is joined by Malavika Solanki, who is a member of the Management Team at the Derivatives Service Bureau. Malavika has worked in the OTC derivatives markets for more than 20 years and is part of the team that not only oversees the DSB, but also previous responsibilities included business development at LCH Clearnet.
Welcome both. It’s fabulous to have you here. Thank you for joining us. I think it was important for the listeners to take some time to pick through how ANNA and the DSB work together, it’s structure, etc. But actually, where I’d like to begin our conversation today is to talk about what’s keeping your members awake at night? What’s going on at the moment, the current state of the industry? Emma, should I come to you first of all?
Emma: Just to touch on a little bit about the ANNA members and partners, which you already captured in your intro, ANNA has members and partners, which spread across 120 jurisdictions and each of these have the pressure of being a key market infrastructure within their markets. We’re talking firms such as CSDs, exchanges, central banks, supervisory authorities, and data vendors. Our experience is that these entities play key roles and they’re core to the functioning of their local financial markets. They also need to ensure the continued interoperability on a global scale.
Their ability to really implement business continuity plans during this COVID-19 time, as well as seamlessly continue to support their markets during a period of volatility, is a testament to their role and function within their jurisdictions. But that role does come with the pressures of being able to maintain that stability with their market participants.
The DSB is in a very similar position, being key for market participants to have to fulfill their regulatory obligations. So again, we’re respecting the needs of the user community, listening to them in order for us to assess how we move forward in the best way possible for them to continue to meet their needs. But so we can continue evolving and developing the service. I’m sure Malavika can build on that.
Julia: Malavika, I was going to bring you in here actually, because obviously, DSB is the main area that you’re focused on as well. Of course, during COVID times it’s fascinating. I started my intro talking about how it’s all about reference data and standardisation of data, but it sounds from what Emma was saying that actually that the role has shifted slightly as everybody’s trying to figure out how to navigate these times.
Malavika: That’s the most accurate way of describing it, with so much going on that the most immediate need is a human need and it’s one of stability and organisations. Fundamentally, data matters and standardisation matters, but the first thing is to secure the organisations, make sure that teams are comfortable, that they’re comfortable operating in the new environment, that once that stability can be delivered and facilitated, then one starts to look at, what does that mean in terms of technology and data?
If I think back to the early weeks, and in fact, the first week I had come home, the week before the lockdown, where we had begun working from home already, the number of clients I had on the phone to me that week was quite astronomical. Everyone was trying to learn from everyone else: “what is going on right now? What have you heard? What is your expectation for how long we’re going to be home?” That’s a need for stability to Emma’s earlier point.
Once you get that stability in terms of people, mental health, wellness, basic organisational infrastructure, what we then started to see is that the things that are now keeping them up at night, those aspects continue. But now that we’re into the third or fourth month of this world, the focus is very much now on the future and how best to adapt to it. With so much going on in the OTC derivatives market on a number of different fronts it’s very much about how does an institution shape the future to best suit their competitive strategy? If we’re talking specifically within the context of data, and if that is the new oil, at least that’s what people seem to say it is, well then how do you organise it and facilitate it, and utilise it to suit your organisational purposes?
Part of that is data alignment and standardisation and that is a foundational stone, the cornerstone. Once you get past that, the next piece becomes, how do you then take it so you can save costs and streamline operations, but also how do you build that into your AI plans, your plans for the future on the revenue side of the equation? That’s very much now what is starting to keep our users up at night.
Julia: When you were talking about AI, you mean obviously artificial intelligence, and everybody in the world of capital markets, in particular in the world of derivatives trading, is thinking about how do you apply artificial intelligence in your end to end data flow as well? It feels really, really essential and important, but also critical in these times as well.
What I’m thinking about also is while we’re all focused and have been focused on the COVID lockdown, and now thinking about what the future’s going to look like and the new working models, I’m really keen to hear if we are at risk of ignoring anything? Because priorities have shifted because consideration has gone elsewhere. Emma, can I ask your thoughts on that? Is there anything we’re at risk of ignoring?
Emma: I think the priority has definitely been, and the focus has been, on how do we keep things running? But we can’t remain stagnant and not continue to evolve and progress. I think there is the need to make sure what you were planning to achieve is still very much on your radar. Then maybe that your deliverables and the timelines need to shift because it’s just a fact that everyone has had to move all of their priorities to either transition and set up for remote working, or for those who weren’t as well prepared, start to implement and put those measures in place. It’s only, I think now that everyone is in the full flow, you’re seeing the new normal, shall we call it, and everyone working.
I think now we’re busier than ever because no one’s travelling. You can’t go anywhere. So everyone is at their desk all day, every day, and the work, the productivity in my mind has just increased. We have the time and the capacity to start exploring and revisiting those items which may have been temporarily put aside whilst we were focusing on the business as usual, and that is really, really important.
The DSB did consider what was needed as part of our annual consultation process this year, which feeds into how we evolve the service in the following year, so for our 2021 service provision. We did bear this in mind when we were shaping the consultation and only those items really we thought were key. We wanted to ensure that we minimised the additional effort and resource that was needed by our stakeholders at this critical time.
At the same time, we needed to maintain the timeline as we have in effect, so we can continue to deliver what our users need. With the consultation, we focused on those topics that were key for our service evolution for 2021, and that we’d had particular interest from our stakeholders to take forward. That has meant our prioritisation has focused on what we see as essential and what our community has told us is essential to move forward, whilst everyone can remain focused on their business as usual, and continue to keep that at the standard they need, so we can progress once things settle down and everyone can move forward.
Julia: Emma, the consultation process sounds incredibly important because of course, industry engagement across all your members and the entire world is essential. Really keen to hear then what are those key priorities that your members and the industry have told you matter? Let’s start with DSB. Malavika, can I hear your thoughts on that?
Malavika: The primary things that came out of the consultation paper can be classified as items relating to functionality, to data enhancement, to cybersecurity, and then a matter on our legal agreement. Thinking specifically about what that means in terms of the users, what arose from this was actually quite fascinating in that one of the items relates directly to operational enhancements that the DSB can make to facilitate our users increased digitisation and specifically robotic process automation, and how the way in which we communicate our day-to-day changes can help feed into the way the users themselves are evolving their organisations and their own technology platforms.
That is directly related to this idea of what is changing and how do we fit into it? That’s a fairly mundane but fundamental item. There were two other aspects that related to the way in which the DSB provides services to our users. What the industry approved was the DSB in essence introducing two new service levels in terms of how we facilitate our users.
One was for users to be able to come in and programmatically search for data at a much lower threshold because we’re starting to see new types of institutions want to access the DSB. Two and a half years after MiFID II, one of the things that’s remarkably fundamental about the state of the industry and how it impacts the DSB is that we’ve noticed that the industry seems to be moving from a pure implementation model, which is go live at any price, at any cost, with any framework, to more of an optimised model, where they’re starting to look at how they consume the data, where they get it from, how they can optimise those inputs. Therefore, institutions that may have been coming to us once a month three years ago, or two and a half years ago, are now coming into us more regularly to consume data in a different manner. The idea is to provide services that facilitate that.
There is then a piece of work that industry has approved around a piece of analysis for the DSB to do over the course of the next year, to look at how we create financial instrument shortening. Again, what’s fascinating is this goes to the way industry practice is evolving. It’s something known as a FISN and literally stands for Financial Instrument Short Name. It’s a summarised way of describing the instrument you’re talking about, and there is an ISO standard that fits for this, and the ISO standard allows a remarkable amount of flexibility in how you can address things as it needs to.
What’s been fascinating is as the data from the DSB has started to be utilised by our users in areas beyond pure regulatory reporting, we’ve found that our users, in essence, have asked us to undertake a piece of analysis next year to look at how that instrument short name is composed and whether it can be enhanced to allow them to make better use of it in non-regulatory manners. That has quite interesting implications for the way in which the use of data is evolving strategically in the financial services market.
The next two items were around cyber security and specifically doing cost-benefit analysis and a risk assessment of the DSB’s core technology infrastructure. The rationale for this really is as the DSB evolves from serving almost 500 institutions who were primarily located in Europe, to serving a global community of institutions, as the Unique Product Identifier or UPI comes along, it’s really conducting a risk assessment of the core technology infrastructure and making sure that those can continue to evolve in a way that best serves the marketplace.
Last but not least, we had a question in the consultation around the manner in which the DSB handles legal disputes when it comes to arbitration. A technicality, but fundamentally important in making sure all our users can be fairly treated.
Julia: Great. That’s enormously helpful just to get a sense of where we have the big, high-level concerns that the industry is thinking about, and also how you’re engaging both as ANNA and DSB in helping clients think about members, I should say, or institutions around the world as well, participants, let’s call them. Thinking about the dynamics at play, but also your role in helping them as well.
I’m quite interested, as we’ve gone through the coronavirus lockdown, in hearing about what you have learned about the shifting dynamics in terms of what your users or members need, building on what Malavika was saying about the consultation paper. Any key learnings come out of that?
Emma: Malavika also touched on it earlier around the need to have the continued interaction and collaboration with not only our teams internally, but also with external stakeholders. Knowing that we’re still available, that we’re still moving forward, we’re still listening to what is needed in order to evolve the service is fundamental really for making sure everyone can continue to move on once things progress, but also that we can just continue evolving from now.
It also touched on how artificial intelligence and machine learning. I think in this current environment with COVID-19, digitalisation is so important, and firms who may have been focusing on this as I think we’ve all been working in an ever digital environment for the last couple of years, but even more so with this current situation, firms have realised this is a necessity. We have to have digitalisation to ensure we have the appropriate collaborative tools and accessibility to what is needed for us to all be working together as if we can still have face-to-face meetings.
I think that is key for us to continue having operational efficiency and having the right material for decision making: the data alignment, the accuracy and that pool of information being readily available is really key. I think that’s a very positive thing that’s come out of this current situation, is that everyone is much better prepared from a digitalisation standpoint or knows what’s needed to be achieved in order for us to really utilise that to its full capabilities.
Julia: One thing that I’ve been particularly talking to leaders of industry bodies about of late is how the role of industry associations really matter at times like this. I suppose my next question really is if there were one or two things that you’d want listeners and your members to pay particular attention to now, and to engage with you on, what might that be? Malavika, from a DSB perspective, can I come to you first?
Malavika: If I was to pick two things, I think the two I would start with would be first around data semantics and alignment. Specifically, what does that mean? That means making sure that we work together, to your point about collaboration and the need to engage in a consistent manner, what I’d like to see us do is make sure that we as institutions, regardless of where we sit in the financial marketplace, that we as institutions work together to make sure that we agree common definitions for what each data attribute means. That we agree on a common set of values that will be used in that space and then understand why we’re doing that.
Because if we’re going to move into a world of increasing AI, if we do not share the same common definitions of what a particular word, as much as Merriam-Webster’s or the Oxford English Dictionary provides, if we don’t have common definitions of what words mean, in essence, we will use those words differently and end up with enormous model risk in our system. If the future is going to be built on utilising data as well as people, you need that data to at least mean the same thing at a grassroots level so you can utilise it in a way that serves your organisation.
Julia: Malavika, it’s really interesting, isn’t it? Because I think of the number of conversations of panels that I’ve chaired about artificial intelligence, the quality and integrity of the data and the consistency, and right the way down to the granularity of its formation, it’s vernacular, it’s language really, really matters.
Emma, looking from an ANNA perspective, which of course is the entire association of national numbering agencies within which DSB sits, any other key points that you would really want listeners to pay attention to as they think about the road ahead, perhaps?
Emma: I think what Malavika mentioned really resonates just with the general topic of standardisation and that is the fundamental mission of ANNA, which is around fostering standardisation across the global financial services community.
Now, the standards that we are responsible for, and broadly encourage adoption of, relate to the identification, the description and the classification of financial and referential instruments, as well as complementary standards that work with the standards that our national numbering agencies are responsible for to build additional benefit through those complementary efforts. For example, with the Legal Entity Identifier.
Now, ANNA is working in partnership with GLEIF, which is the Global LEI Foundation. They’re responsible for the implementation and adoption of the LEI standard, which can be used to identify issuers. It’s completely complementary to the ISIN standard, which represents the details for issuances. Together you have a way of improving risk management and efficiency through the use of these two international standards.
We’re encouraging all national numbering agencies of which 19 have already opted in to the initiative, to integrate the LEI standard into their ISIN record databases. Then this data is being provided freely available as an open data source on the GLEIF website. Now, this is a fantastic tool that can be used by all stakeholders and will allow much improved risk management and data aggregation, and that’s particularly important at times like this one when markets are particularly volatile.
Julia: Of course, when we talk about industry associations, part of it is a relationship with your members around the world, and also then thinking about you as an organisation. But also I’m really keen to hear, this is a question I’m asking all leaders who have been on the podcast as well, which is what have you as individuals being paying attention to for yourselves during these times of lockdown and working at home? Emma, let me come to you first of all, is there a particular TV show or something that you’d recommend to listeners that has kept you going?
Emma: Definitely. I do have a, I suppose, bad habit at the end of my working day, which can often be quite long, that I just want to zone out. So I do put on Netflix or something at the end of the day. I have recently watched, I did a few nights of binge-watching, “Little Fires Everywhere,” which features Kerry Washington and Reese Witherspoon. I was really so captivated by it, which is why I did the binge-watching, but really it’s about this entangled story of two families, but it raises and explores really fundamental topics such as racism and stereotypes, feminism, roles of mothers, and family dynamics, community, and I would definitely recommend it.
Julia: Fabulous. The great thing about programs like that – one episode is never quite enough. Malavika, so what’s been keeping you going during lockdown?
Malavika: Friends, Mental Wellness, a lot of TV and a bit of light reading. Briefly looking at the TV pieces, if we start from the entertainment stuff, given the times we live in, I revisited 13th on Netflix. I’d first seen it at the BFI a few years ago on the big screen, and it makes for powerful viewing in the current context.
I also quite liked “The School That Tried to End Racism,” which was a program on Channel 4, just for the hope that it offers children and society in years to come if we’re willing to take a step together in a different direction. Then on the more light entertainment front, I have greatly enjoyed watching “The Old Guard” last week, which is nothing but pure mind candy, but I recommend it.
Julia: Another question I’m also asking leaders, aside from what they’re watching and what they’re listening to at the moment as human beings, is there a piece of regulation that you’re particularly paying attention to? Is there a piece of policy or legislation that is taking your focus at the moment?
Emma: The standards under ANNA’s responsibility or the National Numbering Agencies’ responsibility, the ISIN, the CFI, the FISN standards, have really been prevalent in quite a number of European regulations over the last couple of years. MiFID II and MIFIR, the market abuse regulation, CSD regulation, prospectus regulation, there has really been a lot of use and benefits gained from the broad global adoption of these standards pulled into European regulation.
A fairly new regulation, although it’s been known about for a little while, but has just launched, is the Securities Financing Transactions Regulation. That has been on the broader ANNA front as something of interest given the broad use of the standards that are within our responsibility. We’ve been working with other trade associations and industry stakeholders to look at the needs from the industry, from the standards that we’re responsible for, and how we can assist and facilitate market participants to have the most comprehensive information they need in order to fulfill their regulatory obligations.
One of those points, which I have also touched on, is to do with the ISIN and the LEI linkage. That’s a fundamental piece as part of the SFTR. That’s something I would say that has been in the forefront of our minds at the moment.
Julia: I know that SFTR is something that the industry is particularly talking about at the moment. That feels incredibly timely, but also a great opportunity for people to get engaged with you thinking about how to address some of the dynamics around that piece of regulation as well.
Emma: Definitely. Well, the same issues have arisen with regards to third country requirements. That is where our collaborative efforts with our members, given that we have outreach and are assigning ISINs in more than 220 jurisdictions, trying to ensure that even though these aren’t regulatory requirements in these third country jurisdictions, that there are impacts and consequences if the relevant reference data standards aren’t available for those instruments that fall within the scope within the European regulation.
We really do need to educate our numbering agencies to let them know the importance of applying the standards and ensuring that the appropriate coverage exists for any instrument in their jurisdiction that will be traded in Europe and fall within the scope of the variety of regulations that are in effect. That is part of ANNA’s mission, it’s something that we continue to do.
Our statistics are great at the moment with regards to coverage. On a global basis we have over 90% coverage in both the CFI, FISN, and also with regards to LEI coverage, roughly 50% of ISINs also have an LEI linked to them in the ANNA Service Bureau database. We are seeing progress and things are moving in the right direction. LEIs can only be assigned to or mapped to ISINs where an LEI exists. Ensuring our numbering agencies can also educate their market participants to increase the use and prevalence of these standards is really important.
Julia: SFTR clearly on everybody’s minds as well. Malavika from the DSB perspective, any particular regulation you’re paying attention to right now?
Malavika: There have been two pieces of legislation that have been front and centre certainly of my mind, and I suspect for most of the DSB users. The first being an ESMA consultation that closed recently on non-equity transparency under MiFID II. Essentially that covers a number of data standardisation aspects for OTC derivatives.
The second piece of legislation is EMIR Refit. Again, a consultation by ESMA, that particular consultation is within the European context, but from a user perspective, the Unique Product Identifier or the UPI is something that is going to have global implications for listeners in almost every jurisdiction that one can imagine. Those two pieces of legislation have certainly taken up the majority of my mind space from a professional perspective over the last few months.
Julia: It’s been a wonderful conversation today. Emma and Malavika, I can’t tell you how much I’ve really enjoyed this. It’s incredibly important that we do spend time with industry associations thinking about not only their role for the industry as a whole globally, but also what their members and participants, and the industry at large should be really paying attention to, particularly in the context of data as well.
If anybody wants to find out any more about ANNA and DSB there are two websites. ANNA, the Association of National Numbering Agencies can be found on anna-web.org. The Derivative Service Bureau is anna-dsb.com. Of course, you can find them on social media as always @ANNA_ISIN and @DSB_ISIN.
Thank you both very much indeed for joining us today. It’s been a fantastic discussion. Emma, thank you for joining us.
Emma: My pleasure. Thank you so much for having me.
Julia: Malavika, it’s been wonderful to have you on the show. Thanks so much for joining us today.
Malavika: Thank you for having me, Julia. It’s been an absolute pleasure.
Julia: Thank you as always to all our listeners for tuning in. My name is Julia Streets, and today you’ve been listening to StreetsTalksTo ANNA and DSB.
Kieron: This episode of StreetsTalksTo was produced by me, Kieron Yates, on behalf of Streets Consulting Limited. Streets Consulting is a business development, marketing communications consultancy that’s focused on helping FinTechs from the smallest startup companies to some of the world’s largest global organizations. Everybody’s trying to innovate and everybody’s trying to grow.