Sep. 29, 2020
Subject: File No. S7-08-20 From: Tosha Ellison Affiliation: COO, FINOS -------------------------- September 29, 2020 We welcome the opportunity to respond to the SEC's question regarding permission to provide other identifiers for securities/financial instruments in reporting (question 25). As a basic principle, the Fintech Open Source Foundation (FINOS) supports the use of open data, as it increases transparency, reduces industry costs, and enables interoperability. In that regard, we would support granting permission to provide other identifiers, where they meet certain basic qualities specifically that they conform to generally accepted open data standards, include descriptive information, and both the identifier and descriptive information are publicly accessible without restrictions on access, use or other barriers. This would have a beneficial effect in increasing transparency, interoperability, and accessibility to data by firms, investors, and the general public. FINOS is currently working on a project, through the Securities Reference Data Project, to enable better mapping across various identifiers in use in the industry, encourage use of open data to solve common industry problems, and reduce unnecessary costs to the industry. Please note that several FINOS members may be responding directly to the proposed changes and this response may not reflect their views.