The Hidden Costs of CUSIP Licensing (and How to Mitigate Them)

1. Introduction: The Indispensable CUSIP and Its Veiled Financial Burden

The Committee on Uniform Securities Identification Procedures (CUSIP) number is a cornerstone of North American financial markets. These 9-character alphanumeric identifiers are assigned to the vast majority of financial instruments, including stocks of all registered U.S. and Canadian companies, commercial paper, and U.S. government and municipal bonds. Their fundamental purpose is to provide unique and unambiguous identification, thereby facilitating the efficient trading, clearance, and settlement of securities. This critical infrastructure, formally known as CUSIP Global Services (CGS), is owned by the American Bankers Association (ABA) and operated by S&P Global Market Intelligence. FactSet acquired CGS in 2021, and its role in past legal challenges and operational management remains relevant for context.

While the direct licensing fees associated with CUSIP usage are a known cost for financial institutions, a more complex and often unquantified array of indirect financial and operational burdens lies beneath the surface. These “hidden costs” can manifest in various forms, including operational inefficiencies stemming from integration and data management complexities, the significant weight of compliance and regulatory obligations, substantial legal, negotiation, and audit expenditures, and notable restrictions on data usage that can impede innovation and product development. 

Furthermore, the economic impact of CGS’s dominant market position contributes to this less visible financial strain. The very indispensability of CUSIPs, mandated or implicitly required for core market functions and regulatory reporting, creates a situation where financial firms have limited alternatives for this specific identifier. This dependency may allow for a pricing and licensing model against which firms possess minimal negotiating leverage. Consequently, firms often find themselves absorbing not only direct fees but also these indirect costs as they navigate or attempt to work around restrictive terms and the complexities of the CUSIP ecosystem.

For financial institutions, a comprehensive understanding of the total cost of CUSIP ownership is not merely an accounting exercise; it is a strategic imperative. Such understanding is crucial for effective budgeting, enhancing operational efficiency, robust risk management, and making informed decisions regarding the firm’s financial data infrastructure. The debate surrounding CUSIP licensing transcends mere fee structures; it touches upon fundamental issues of market infrastructure control, the openness of financial data, and the potential for innovation within financial data services. This report aims to dissect the multifaceted costs associated with CUSIP licensing—both apparent and concealed—and to provide actionable, research-driven strategies for financial institutions to mitigate these significant financial burdens.

The Hidden Costs of CUSIP Licensing (and How to Mitigate Them)

2. Understanding the CUSIP Framework: System, Governance, and Licensing

A thorough grasp of the CUSIP system, its governance by CUSIP Global Services (CGS), and the intricacies of its licensing model is foundational to identifying and addressing the associated costs.

 

2.1. What is a CUSIP?

A CUSIP number is a unique 9-character alphanumeric code designed to identify financial instruments. Its structure is systematic and hierarchical:

  • The first six characters identify the issuer, such as a company, municipality, or government agency. This segment follows an alphanumeric convention linked to the issuer’s name. For instance, in the CUSIP for FactSet Research Systems Inc – Common Stock, “303075” represents the issuer.
  • The next two characters (seventh and eighth) denote the type of financial instrument (e.g., equity, debt) and uniquely identify the specific issue within that issuer. For the FactSet example, “10” signifies the issue.
  • The final character (ninth) is a check digit, mathematically derived from the preceding eight characters to ensure the accuracy of the identifier. In the FactSet CUSIP “303075105”, “5” is the check digit.

 

The primary purpose of CUSIPs is to provide a universally recognised and unambiguous identifier for financial instruments within the U.S. and Canadian markets. This standardisation is critical for efficient trading, clearing, settlement, regulatory reporting, and portfolio management.

Several related identifiers are also managed under the CUSIP umbrella:

  • CINS (CUSIP International Numbering System): This system is used for securities issued outside of North America. CINS identifiers maintain the 9-character CUSIP structure but incorporate a letter in the first position to indicate the issuer’s country or geographic region.
  • CEI (CUSIP Entity Identifier): This is a 10-character alphanumeric code designed to uniquely identify legal entities participating in the syndicated loan market.

 

2.2. CUSIP Global Services (CGS): The Powerhouse Behind the Identifier

CUSIP Global Services (CGS) positions itself as the “trusted originator of quality identifiers worldwide” and the industry standard for reliable, timely reference data. Owned by the American Bankers Association (ABA), CGS is managed by S&P Global Market Intelligence. CGS is responsible for assigning CUSIPs, CINS, and, in the U.S. and other designated territories, International Securities Identification Numbers (ISINs).

CGS emphasises its role in ensuring the smooth operation of essential front- and back-office functions, thereby enabling efficient communication and management of financial transactions. With over five decades of focus on standardisation, CGS aims to provide a solid foundation for businesses in the financial sector.

Key services offered by CGS include:

  • CUSIP Access: A web-based platform providing lookup and download capabilities for the entire CUSIP universe. This service covers more than 50 million financial instruments, offering up to 62 distinct data elements for each, and features real-time updates every five minutes. It also includes information on corporate actions, Legal Entity Identifiers (LEIs), and linkages for private securities.
  • Database Services: The extensive CGS database, containing over 65 data elements for tens of millions of financial instruments, serves as a critical backbone for Security Master Files used by vendor and user firms throughout the industry.
  • Identifier Assignment: CGS manages an online application process for new identifiers. Its operations team reviews offering documents to extract the necessary data elements to ensure the uniqueness of each assigned identifier.

 

2.3. The CUSIP Licensing Maze: Models and Fee Structures

The CUSIP licensing model is multifaceted, with different categories of users and various triggers for licensing obligations. Understanding these nuances is crucial for cost management.

User categories are generally defined as:

  • Direct End User Customer: An entity that obtains access to a CGS product or service directly from CGS.
  • Indirect End User Customer: An entity that receives the benefit of CGS Data through one of CGS’s Authorised Data Vendors.
  • Authorised Data Vendors: These are typically information vendors or outsourcing providers who incorporate CGS Data into their own products or services, or who perform outsourced operations (like trade processing or portfolio accounting) on behalf of end-user customers.

 

A CGS license is generally required when an end-user customer subscribes to a CGS product or service directly, or when they obtain the benefit of CGS Data indirectly through an Authorised Data Vendor, particularly for electronic downloads, data feeds, or bulk retrieval of CUSIP data. If an end-user’s database containing CUSIP Data is updated, stored, maintained, or operated by an Authorised Distributor, a license is also typically necessary. An exception exists for users who only read or view CGS Data via an authorised vendor’s online screen display without downloading or exporting the data, provided this access is not part of an outsourced solution.

The calculation of license fees for end-users is based on their specific “Usage of CGS Data”. This “usage” is a critical definition. For instance, if a firm holds positions in 5,000 securities but its internal research or trading processes involve analysing a universe of 30,000 CUSIPs to select those holdings, the licensing fee may be based on the larger 30,000 figure. Conversely, if a firm receives a feed of 30,000 CUSIPs but demonstrably limits its use to only 5,000 related to its positions, the fee might be based on the lower count. This distinction underscores the importance of meticulously tracking and defining internal data workflows, as the interpretation of “benefit” or “usage” can significantly impact costs. The factors influencing these fees are detailed in Table 2.

End-user customers are required to complete a Use of Service Statement (UOSS), a self-declaration of their CUSIP data usage, which CGS then uses to determine the appropriate license fees. While this is a self-declaration, CGS ultimately determines the fee, creating a dynamic where precise internal understanding of usage is paramount. The complexity of this licensing model and the fee calculation process itself necessitates significant internal due diligence by financial firms, which represents an often-overlooked hidden cost.

In addition to ongoing licensing fees, CGS charges assignment fees for the issuance of new CUSIP identifiers. These fees vary depending on the type of offering, as shown in Table 1. Express services for faster assignment are available at a premium.

Table 1: CUSIP Assignment Fee Schedule Highlights

Offering Type

Fee per Identifier / Fee Structure

Express Service Surcharge

Single CUSIP Identifier Offering

$210

50% over regular fees

Offering with Multiple Maturities/Classes

$210 for first; $34 for each additional (unlimited)

50% over regular fees

Short-Term Municipal Anticipation Notes (e.g., BANS)

$105 per identifier

50% over regular fees

Short-Term Retail Brokered CDs (<1 yr maturity)

$105 per identifier

50% over regular fees

Hedge Fund Requests

$200 for first; $50 for each additional series

50% over regular fees

Retail Brokered CDs via REACH (<1 yr maturity)

$131 per CD

50% over regular fees

Retail Brokered CDs via REACH (≥1 yr maturity)

$257 per CD

50% over regular fees

Source: Fees are subject to change by CGS.

Table 2: Key Factors Influencing CUSIP Licensing Fees for End Users

Factor

Description of Impact on Fees

Relevant CGS Policy/Document

Number of CGS Identifiers Used/Accessed

Primary driver of the base fee. Includes CUSIP, CGS CINS, and CGS ISINs.

Use of Service Statement

Number of Business Lines Using Data

Additional business lines beyond the primary one typically incur a percentage add-on to the base fee (e.g., 50% for second line).

Use of Service Statement

Number of Regions with Access/Usage

Similar to business lines, additional regions beyond the primary one incur percentage add-ons to the base fee.

Use of Service Statement

Source: Fee calculation details can be complex and subject to CGS determination.

Certain fee waivers or exemptions exist. Notably, no license fee is typically charged if an end-user accesses or uses fewer than 500 unique CGS identifiers, although a license agreement might still be required. CGS also states a policy of completely waiving licensing fees for investment advisory firms with less than $5 billion in client assets under management (AUM), claiming that 95% of such firms do not even require a license.

The licensing model, which charges both end-users and Authorised Data Vendors for their respective “uses” of CGS data, effectively creates multiple revenue streams for CGS from the same underlying dataset. While CGS clarifies that vendors are not charged for their end-users’ specific use and vice-versa, the data originates from CGS and is monetised at various points in the distribution chain. This structure can contribute to the overall cost burden experienced by the industry, as vendor costs may be passed on to end-users in addition to any direct CGS license fees they incur.

3. Beyond the Invoice: Uncovering the Hidden Costs of CUSIP Licensing

The direct fees for CUSIP assignment and data usage represent only the tip of the iceberg. A significant portion of the true cost of CUSIP licensing is submerged in various operational, compliance, legal, and strategic expenditures that are often harder to quantify but can substantially impact a financial institution’s resources and agility.

3.1. Operational Overheads and Integration Complexities

Financial institutions face considerable operational expenses related to the integration and management of CUSIP data. Integrating CUSIP data feeds into diverse internal systems, such as trading platforms, risk management tools, compliance software, accounting systems, and client reporting mechanisms, requires significant IT development effort, ongoing data mapping, and continuous maintenance. For example, security master platforms, essential for organising instrument data, must integrate feeds from various vendors that carry CUSIP information, and maintaining these interfaces is a recognised “hidden cost to data management”.

The challenge is compounded when firms, due to cost or restrictive licensing terms, resort to using alternative or proprietary identifiers alongside CUSIPs. This necessitates complex mapping processes between different identifier systems, increasing the risk of data inconsistencies and operational inefficiencies. Retirement plan advisors, for instance, if denied CUSIP access, must find alternative solutions, often dealing with proprietary IDs that differ across recordkeepers, which demands extensive internal record-keeping and updates to their “security master” files. The financial landscape is populated with a range of trade identifiers (ISIN, CUSIP, SEDOL, FIGI, etc.), many of which are “closed” systems, contributing to a fragmented identifier environment that firms must navigate.

Ensuring the accuracy and consistency of CUSIP data across all internal systems is paramount. Discrepancies can lead to costly trade breaks, settlement failures, incorrect regulatory reporting, and ultimately, client dissatisfaction. The effort involved in data validation, cleansing, and reconciliation represents a substantial, often ongoing, operational cost. While not always CUSIP-specific, the challenges of migrating fund administration due to “messy data,” “extensive gaps, inconsistencies and errors” highlight the general costs associated with poor data quality, which can be exacerbated by difficulties in managing financial instrument identifiers. Indeed, a significant percentage of fund administrators cite data acquisition and governance as their primary operational challenge, with major concerns around data availability, accuracy, and timeliness.

 

3.2. The Weight of Compliance and Regulatory Reporting

Adherence to CUSIP licensing terms imposes direct compliance costs. Financial firms must invest in systems, processes, and personnel to ensure they are using, storing, and distributing CUSIP data strictly according to the license agreement. This includes tracking data flows, managing user access, and ensuring that any redistribution, whether internal or external, is permissible. The complexities of CUSIP licensing are often described as more than just a regulatory hurdle; they can create significant barriers and compliance costs, particularly for smaller and mid-size firms.

Furthermore, many regulatory reports submitted to authorities like the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) require CUSIPs for the precise identification of securities. Ensuring the accuracy of this CUSIP data in regulatory filings is critical to avoid potential penalties and reputational damage. The systems and controls required to maintain this level of accuracy for reporting purposes carry their own associated costs. CUSIPs are deemed “critical to…regulatory reporting”, and CGS itself highlights that CUSIP “plays a vital role in…regulatory reporting, ensuring streamlined operations and compliance”. The Financial Data Transparency Act (FDTA) and the ensuing discussions about common identifiers also bring compliance considerations to the forefront, as CUSIP’s proprietary nature and lack of an open license could present future challenges if data standards evolve.

 

3.3. Legal, Negotiation, and Audit Expenditures

The process of engaging with CUSIP licensing often involves significant legal and negotiation expenses. CUSIP license agreements are typically complex legal documents, not simple “click-through” contracts. Firms frequently require legal and procurement expertise to decipher the intricate terms and negotiate agreements that align with their specific usage and risk tolerance. Key areas requiring careful legal scrutiny include the definitions of licensed data and usage, the grant of rights, territorial limitations, field of use restrictions, and the terms for renewal and termination.

CGS retains audit rights to verify compliance with license terms. Financial institutions must therefore dedicate resources to prepare for, manage, and respond to these audits. Such audits can be disruptive to normal business operations and time-consuming for staff. If non-compliance is discovered, firms can face substantial penalty fees and may be required to purchase broader, more expensive licenses retroactively. The terms of use often explicitly state that any use of CUSIP data outside the specific licensed scope (e.g., beyond clearing and settlement without an appropriate license) may require an additional license and associated fees, and CGS reserves the right to seek injunctive relief for misuse. These audit rights and the potential for penalties create a compliance pressure that itself is a cost.

In instances of alleged unlicensed use or copyright infringement (a claim CGS and the ABA have historically asserted), firms can face the threat or reality of legal action, leading to substantial legal defence costs. The class-action lawsuit filed by Dinosaur Group and Swiss Life Investment Management, for example, highlights allegations that CGS “strongarms financial firms to pay fees” and threatens to cut off CUSIP access if firms do not comply with licensing demands. The very possibility of such disputes necessitates careful legal review and risk assessment.

 

3.4. Constraints on Data Usage, Innovation, and Competitive Agility

CUSIP licenses frequently impose strict limitations on how the licensed data can be used, stored, and redistributed, both internally to different departments or affiliates and externally to clients or third parties. For example, license terms may prohibit the creation or maintenance of a master file or database of CUSIP identifiers or descriptions if it’s intended to serve as a substitute for a CUSIP service. Similarly, general financial data licenses often restrict users from publishing, retransmitting, or otherwise reproducing the information in connection with any commercial enterprise beyond specifically permitted uses.

These restrictions can significantly stifle innovation and prevent financial firms from developing new data-driven products, analytical tools, or client-facing applications that could leverage CUSIP data in novel or more efficient ways. The cost of obtaining licenses for broader or more flexible use rights can be prohibitively expensive, especially for smaller firms or fintech startups. This has been termed a “proprietary cost” imposed on the users of the data, where the expense and limitations of accessing essential identifiers hinder the development of enhanced service delivery and data accessibility. While not specific to CUSIPs, research on proprietary costs indicates that when firms face high costs or risks in disclosing or using information, they may become less likely to innovate openly or make certain data widely available. The inability to fully leverage valuable identifier data due to these licensing constraints can lead to missed business opportunities and create competitive disadvantages for firms that cannot afford or secure the necessary usage rights.

 

3.5. The “Monopoly Premium”: Economic Impact of Limited Competition

A recurring criticism of CUSIP licensing revolves around CGS’s market position. As the sole issuer of CUSIPs for U.S. and Canadian securities, CGS operates in what is often described as a “de facto monopoly”. This market structure is frequently blamed for what critics perceive as inflated licensing fees and unfavourable terms, as financial institutions have very limited, if any, practical alternatives for this deeply embedded and often mandated identifier. An SEC Commissioner, for instance, publicly highlighted the “de facto monopoly facing the use of CUSIPs in fixed income markets” as an issue needing attention. The class-action lawsuit against CGS explicitly alleges the charging of “monopolistic fees”.

The absence of direct competition for CUSIP issuance and the core licensing of its use means that financial firms typically have little leverage to negotiate prices or terms downwards. This lack of competitive pressure can contribute to what some might term a “monopoly premium” embedded in the cost structure.

The various hidden costs of CUSIP licensing are not isolated issues but form an interconnected web of expenses. For example, restrictive licensing terms (a hidden cost in themselves) can force firms to develop complex operational workarounds, such as extensive data mapping to alternative identifiers (another hidden cost). These workarounds, in turn, increase the risk of data errors and reconciliation issues, leading to further hidden operational costs in terms of staff time and resources needed for correction and validation.

Furthermore, the legal and audit clauses embedded in CUSIP license agreements act as a powerful deterrent against non-compliance or even against aggressively interpreting use rights in a way that might benefit the firm but challenge CGS’s revenue model. The potential cost of legal action or audit penalties becomes a significant hidden factor influencing a firm’s behaviour. Risk-averse institutions are likely to err on the side of caution, perhaps by paying for broader licenses than strictly necessary or by refraining from innovative data uses that might fall into a grey area of the license. This conservative approach, driven by the perceived risk and cost of non-compliance, indirectly supports CGS’s market power and revenue streams.

The cumulative effect of these direct and hidden costs can disproportionately affect smaller and mid-sized financial firms. These entities may lack the scale, resources, or dedicated legal and procurement teams of larger institutions to absorb these costs or to effectively manage the complexities of CUSIP licensing. This disparity can create competitive disadvantages and potentially impact the broader market structure and the pace of innovation within the financial services industry.

4. The CUSIP Conundrum: Market Scrutiny, Legal Challenges, and Regulatory Responses

The CUSIP licensing model, operated by CUSIP Global Services (CGS) under the ownership of the American Bankers Association (ABA) and management of S&P Global Market Intelligence, has faced sustained criticism and significant legal and regulatory scrutiny over the years. These challenges strike at the heart of its fee structure, copyright claims, and market position.

 

Deep Dive into Criticisms:

The fee structure for CUSIP licensing is a primary point of contention. Accusations of “inflated licensing fees” are common, often attributed to CGS’s “monopolistic” role as the sole issuer of CUSIPs for U.S. and Canadian securities. The cost burden is reported to be particularly heavy for fixed-income instruments due to their sheer volume compared to equities. Licensing fees are typically determined by a combination of factors, including the number of CUSIPs stored or accessed, the number of business lines within an institution utilising the CUSIPs, and the geographic regions in which the CUSIPs are used. This multi-faceted approach can result in annual costs ranging from as little as $10,000 to hundreds of thousands of dollars for financial firms.

A fundamental legal argument revolves around the copyright claims asserted by CGS and the ABA over the CUSIP system and the individual CUSIP numbers. 

Plaintiffs in various legal actions have contended that CUSIPs are factual, systematically generated identifiers that lack the requisite originality and creativity for copyright protection. They argue that the 9-character CUSIP structure is rigid, predictable, and a convention established over 50 years ago, rather than a work of artistic or literary creation. If this argument prevails in court, it could significantly undermine the legal basis for CGS’s licensing model, particularly the charging of ongoing fees for the use of CUSIP numbers beyond the initial assignment cost. While database rights for the compilation of CUSIP data might still exist, the scope of enforceable rights over the identifiers themselves would be narrower, potentially transforming CUSIPs into more open identifiers and drastically reducing costs for the industry.

Allegations of anti-competitive behaviour have also been prominent. The class-action lawsuit involving Dinosaur Group and Swiss Life Investment Management, for example, accused CGS, S&P Global (its former parent/operator), FactSet, and the ABA of violating the U.S. Sherman Antitrust Act by stifling competition and charging monopolistic fees. The alleged tactics include threatening to cut off access to CUSIPs for firms that refuse to pay disputed fees and pressuring third-party data vendors to enforce CGS licensing terms on their own clients.

 

Landmark Legal Cases:

The most notable recent legal challenge is the class-action lawsuit filed in New York by Dinosaur Group (a U.S. broker-dealer) and Swiss Life Investment Management (a Swiss fund management firm) against CGS, S&P Global, FactSet, and the ABA.

  • The lawsuit alleges violations of the Sherman Act and U.S. copyright law.
  • A core argument is that CUSIPs are not copyrightable due to their factual and systematic nature, meaning there should be no right to charge ongoing license fees for their use.
  • The plaintiffs claim the defendants engage in “exploitative conduct” by using their market dominance to charge “monopolistic fees” and prevent the emergence of a competitive market for U.S. securities identification.
  • The lawsuit seeks to recoup over US$1 billion in past payments and damages for the affected class members, defined as financial firms that have paid CGS licensing fees over the preceding four years.
  • The case highlights that CGS’s licensing agreements with third-party data providers are central to the antitrust allegations, suggesting these agreements are used to extend CGS’s control and fee collection mechanisms throughout the data distribution chain.

 

Regulatory Perspectives and Actions:

  • U.S. Securities and Exchange Commission (SEC):
    • The SEC has been a focal point for industry concerns. Former SEC Commissioner Daniel Gallagher publicly criticised CUSIP’s “de facto monopoly” in the fixed-income markets and suggested that the SEC should consider removing references to CUSIPs from its rules. This was a significant development, marking the first public expression of concern from an SEC official on this matter.
    • Various industry groups, including the Bond Dealers of America, the Investment Adviser Association, and the Government Finance Officers Association, have formally lobbied the SEC, calling for changes to CUSIP Global Services’ fees and licensing practices.
    • However, direct SEC intervention faces hurdles. CGS is not an SEC-registered firm, and its for-profit commercial structure differs from many other national numbering agencies (NNAs) worldwide, which often operate on a cost-recovery basis as divisions of exchanges or depositories. Despite these challenges, proponents of SEC oversight argue that it is warranted because SEC rules frequently compel or effectively mandate the use of CUSIPs in regulatory filings and market operations.
    • The passage of the Financial Data Transparency Act (FDTA) has intensified discussions around financial instrument identifiers. CGS has argued that the FDTA does not require the adoption of a common financial instrument identifier beyond the Legal Entity Identifier (LEI) and has urged regulatory agencies to proceed with extreme caution to avoid market disruption if such an identifier were to be chosen. Conversely, other market participants and industry bodies argue that CUSIP’s proprietary nature and lack of an open license do not align with the FDTA’s spirit of promoting nonproprietary, open-license common identifiers where practicable.

  • European Commission (EC):

    • The EC has a history of scrutinising CUSIP licensing practices, particularly concerning U.S. ISINs (International Securities Identification Numbers), which are derived from CUSIPs for U.S. securities. In 2009, the EC initiated proceedings against S&P (then operating CUSIP services for U.S. ISINs) for allegedly abusing its dominant market position by requiring European financial firms and data vendors to pay licensing fees for the use of U.S. ISINs.
    • The EC’s primary allegation was unfair pricing, noting that comparable NNAs in other regions either did not charge fees for ISINs or did so on a cost-recovery basis rather than usage-based licensing.
    • This dispute was settled in November 2011, with CGS/S&P agreeing to offer a lower-cost, lower-value data feed of certain U.S. ISINs for use by market participants in the European Economic Area (EEA).
    • Despite this settlement, several issues reportedly remained unresolved after the EC’s commitments expired in April 2017. These included concerns that S&P was not required to provide all ISINs allocated to instruments in the U.S. and other CUSIP-serviced jurisdictions, that S&P retained full audit rights under model agreements (while financial institutions faced numerous audit requests from various data providers), and that the commitments did not apply outside the EU, hindering global financial operations. European firms continued to report challenges, such as data cut-offs and pressure to sign full CUSIP licenses to avoid service interruptions.

 

The ongoing legal and regulatory battles create a climate of uncertainty for financial firms regarding their long-term data strategies and associated costs. This uncertainty itself can be considered a hidden cost, as firms may delay strategic investments in data infrastructure or adopt temporary, suboptimal workarounds while awaiting greater clarity on the future of identifier licensing. Regulatory bodies appear to be navigating a difficult path, caught between acknowledging the market’s deep reliance on the CUSIP system (and thus hesitating to mandate changes that could be highly disruptive and costly for the industry) and recognising the persistent problems and costs stemming from CUSIP’s proprietary and often expensive nature. This inherent tension likely explains the measured pace of direct regulatory intervention, particularly in the U.S., compared to the more assertive actions taken by the European Commission in the past regarding U.S. ISINs.

5. The Identifier Arena: Assessing Alternatives to CUSIP

The high costs and restrictive licensing associated with CUSIPs have spurred interest in alternative financial instrument identifiers. The most prominent alternatives are the Financial Instrument Global Identifier (FIGI) and the International Securities Identification Number (ISIN). Each presents a different model for governance, cost, and utility.

 

5.1. Financial Instrument Global Identifier (FIGI)

The FIGI is an open standard, unique 12-character alphanumeric identifier designed for a wide array of financial instruments, including common stock, options, derivatives, futures, bonds, currencies, and mortgages.

  • Governance and Cost Model: The structure of FIGI is defined and copyrighted by the Object Management Group (OMG), an international, open membership, not-for-profit technology standards consortium. Bloomberg L.P. serves as the Registration Authority and Certified Provider for the FIGI standard. Crucially, FIGIs and their associated metadata are released free into the public domain, governed by the Open Source MIT License, with no commercial terms or restrictions on their usage or redistribution.
  • Structure: A FIGI consists of a two-character prefix (e.g., “BB”), “G” as the third character (for “global”), an eight-character unique alphanumeric code (which does not contain English vowels A, E, I, O, or U to avoid confusion with numbers), and a single check digit. FIGIs are assigned to unique securities and also to the individual exchanges on which they trade; composite FIGIs exist to represent unique securities across related exchanges (e.g., a single composite FIGI for Apple Inc. common stock traded on all U.S. exchanges, alongside unique FIGIs for Apple on each specific exchange). Once issued, a FIGI is never reused and represents the instrument in perpetuity.
  • Benefits: The primary advantages cited for FIGI are its cost model and openness. Being free to use and redistribute without licensing restrictions is a significant departure from the CUSIP model. Its global scope across asset classes and its aim to streamline trade workflows, eliminate redundant mapping processes, and reduce operational risk are also key benefits.
  • Adoption and Regulatory Acceptance: FIGI has seen growing adoption and regulatory acceptance. It has been adopted or allowed for use by FINRA, for Solvency II and AIFMD reporting in Europe. The U.S. SEC permits FIGI as an alternative identifier in Form 13F, Form N-PX, and certain Short Sale reporting, while the CFTC allows it for Large Trader Reporting. Regulatory bodies in Hong Kong (HKMA, SFC) and Singapore (MAS) also allow its use in specific reporting contexts. Over 1.3 billion FIGIs have been issued for active and inactive financial instruments.
  • Criticisms and Challenges: Despite its advantages, FIGI faces criticisms. A major point is the utility of the data beyond the identifier itself. Critics, including the ABA and CGS, argue that while the 12-character FIGI string is free, the most useful and comprehensive associated descriptive metadata (such as primary exchange details, call features, issuance volumes, issuer names, currency, maturity dates, and coupon rates) is often “locked behind a paywall” and accessible primarily through proprietary Bloomberg terminals or paid data feeds. 

 

The OpenFIGI portal, while free, is said to offer a relatively narrow set of data elements. This leads to questions about whether FIGI is truly “open” and free for all practical purposes if achieving comprehensive data richness requires commercial subscriptions. This nuanced reality means that a simple cost comparison of “CUSIP license fee versus $0 for FIGI” can be misleading; a total cost of data acquisition, integration, and utility must be considered. Furthermore, mandating a switch from the deeply embedded CUSIP system to FIGI would entail significant costs and market disruption for the financial industry, including re-engineering systems, extensive data mapping, and staff training. Concerns have also been raised about FIGI’s fungibility, as it can assign different identifiers to the same security if it trades on multiple exchanges, which some argue is less clear than CUSIP’s general approach of one identifier per security. Regulatory agencies proposing FIGI as a standard have also been criticised for allegedly not conducting a sufficiently robust cost-benefit analysis of such a move.

 

5.2. International Securities Identification Number (ISIN)

ISIN is a globally recognised standard for identifying securities, designed to facilitate cross-border trading and settlement.

  • Structure: An ISIN is a 12-character alphanumeric code. The first two characters represent the country code of the issuer (based on the ISO 3166 standard). The following nine characters constitute the National Securities Identifying Number (NSIN), which is specific to the security within its country of origin. The final character is a check digit.
  • Allocation: ISINs are allocated by the designated National Numbering Agency (NNA) in each country. For securities issued in the United States, the CUSIP Service Bureau (operated by CGS) acts as the NNA and is responsible for assigning ISINs.
  • Relationship to CUSIP: For U.S. securities, the ISIN is directly derived from the CUSIP number. It is formed by adding the “US” country code prefix to the 9-character CUSIP and appending a final check digit. This deep integration means that for U.S. securities, ISIN does not offer an escape from the CUSIP licensing ecosystem. European entities requiring U.S. ISINs have historically faced licensing fee demands from CGS/S&P precisely because these ISINs are fundamentally CUSIP-based and managed by the CUSIP system. Thus, simply opting to use ISINs for U.S. securities does not bypass the CUSIP licensing structure and its associated costs.
  • Global Usage and Benefits: ISINs are the accepted standard in virtually all countries for identifying securities in international transactions, crucial for clearing, settlement, and tracking institutional holdings across markets worldwide. They are intended to support global straight-through processing (GSTP).

 

5.3. Comparative Analysis: CUSIP vs. FIGI vs. ISIN

A direct comparison highlights the distinct characteristics and trade-offs of these major identifiers.

Table 3: Comparative Overview: CUSIP, FIGI, and ISIN

Feature

CUSIP

FIGI

ISIN

Full Name

Committee on Uniform Securities Identification Procedures

Financial Instrument Global Identifier

International Securities Identification Number

Governing Body/Standard Setter

American Bankers Association (ABA)

Object Management Group (OMG)

International Organisation for Standardisation (ISO)

Registration Authority/Operator

CUSIP Global Services (CGS), operated by S&P Global Market Intelligence

Bloomberg L.P. (as Registration Authority & Certified Provider)

National Numbering Agencies (NNAs) in each country (CGS for U.S.)

Cost Model (Identifier & Assoc. Data)

Licensed (fees for assignment & usage); Associated data via paid feeds

Identifier free; Basic metadata free (OpenFIGI); Richer associated data often via commercial feeds (e.g., Bloomberg)

Assignment via NNA (fees vary); U.S. ISIN data linked to CUSIP licensing & commercial feeds

Licensing (Identifier)

Proprietary; License required for most uses

Open Standard (MIT License); Identifier free to use/redistribute

ISO Standard; Licensing for U.S. ISINs tied to CUSIP

Structure (Length, Format)

9-character alphanumeric

12-character alphanumeric

12-character alphanumeric

Geographical Coverage (Primary)

U.S. and Canada

Global

Global (for cross-border identification)

Data Richness (Available w/ Identifier)

Extensive descriptive data available via commercial CGS feeds

Basic metadata via OpenFIGI; More comprehensive data often requires commercial subscriptions

Varies by NNA; U.S. ISIN data richness linked to CUSIP data feeds

Market Penetration

Dominant in U.S./Canada; Widely embedded

Growing adoption; Regulatory nods in specific areas

Global standard for cross-border transactions; Ubiquitous internationally

Fungibility (Identifier per security)

Generally one unique identifier per security

Can have multiple identifiers for the same security based on exchange/market/country

Generally one unique identifier per security globally

Key Advantages

Deeply embedded in N.A. markets; Rich descriptive data available

Free & open identifier; Global scope; Growing regulatory acceptance

Global standard; Facilitates cross-border operations

Key Disadvantages/Criticisms

Costly licensing; Restrictive use terms; “Monopoly” concerns

Questions about true cost/openness of all useful data; Potential fungibility issues; Adoption costs

U.S. ISINs tied to CUSIP costs; Data richness varies by NNA

The choice of a financial instrument identifier is evidently not merely a technical decision but a profound strategic one, carrying significant implications for cost, operations, data governance, and regulatory compliance. Currently, no single alternative identifier fully replicates all of CUSIP’s functionalities and market entrenchment in North America without introducing its own set of challenges, costs, or limitations. This complex landscape underscores the need for financial institutions to carefully weigh these factors when formulating their data strategies.

6. Strategic Mitigation: Taming the Total Cost of CUSIP Licensing

Given the significant direct and hidden costs associated with CUSIP licensing, financial institutions must adopt proactive and multifaceted strategies to manage and mitigate these expenses. A holistic approach combining meticulous internal data governance, informed negotiation tactics, strategic technology adoption, and a pragmatic assessment of alternatives is essential.

 

6.1. Internal Data Governance and Usage Optimisation

Effective cost control begins with a deep understanding of how CUSIP data is actually used within the organisation.

  • Conduct Comprehensive CUSIP Usage Audits: Firms should undertake thorough internal assessments, akin to self-audits, to map precisely how and where CUSIP data is accessed, stored, processed, and distributed across all departments, systems, and geographical locations. This audit must identify all direct CGS data feeds, indirect access via third-party vendors, and any usage in downstream applications or reports. Proactively conducting such License Position Assessments well before renewal periods can help identify potential compliance risks or areas of over-licensing, allowing for remediation. Given that CGS determines fees based on its interpretation of “usage”, which can include the entire universe of identifiers a firm’s processes might touch, not just those for securities held detailed internal tracking is paramount.
  • Align Actual Needs with Licensed Scope: A common source of overspending is a misalignment between licensed entitlements and actual consumption. Many companies pay for unused licenses, subscriptions for data they don’t need, or higher-level service tiers than necessary. Identifying and eliminating “shadow IT”, unapproved software or data subscriptions acquired by individual departments, and consolidating underused applications can yield significant savings.
  • Consolidate Data Feeds and Access Points: Where feasible, centralising CUSIP data procurement and management can eliminate redundant data feeds and individual licenses across different business units or regional offices. Establishing a “single source of truth” for CUSIP data within the organisation, managed under a clear governance framework, can improve efficiency and control.
  • Leverage Fee Waiver Provisions: Firms should actively explore eligibility for CGS fee waiver provisions. For entities with limited CUSIP usage (defined by CGS as fewer than 500 unique CGS identifiers), a license agreement may still be necessary, but the associated fee is typically waived. Similarly, investment advisory firms with less than $5 billion in Assets Under Management (AUM) should confirm their eligibility for CGS’s stated policy of waiving fees for such entities.

 

6.2. Mastering License Negotiation with CGS

Negotiating with CGS requires meticulous preparation and a clear understanding of the firm’s own data requirements and the intricacies of CUSIP licensing terms.

  • Thorough Preparation: Before entering negotiations, firms must have a precise understanding of their current and anticipated CUSIP data needs across all operations. While direct IT price benchmark analysis is challenging due to CUSIP’s unique market position, understanding CGS’s fee drivers allows firms to model potential costs and identify areas for discussion.
  • Scrutinise All Terms (The “Checklist Approach”): Drawing on best practices for intellectual property licensing, every clause in the CGS license agreement warrants careful review:
  • Definitions: Ensure absolute clarity on terms like “Licensed Data,” “Usage,” “Distribution,” “Affiliates,” “Territory,” and “Field of Use.” Ambiguity here can lead to future disputes and unexpected costs.
  • Grant of Rights: The license must explicitly detail all permitted actions: the right to use, display, store, reproduce, distribute (internally and externally), integrate into other systems, and create derivative works from the CUSIP data.
  • Territory and Field of Use: These must be precisely defined to match the firm’s operational footprint and business activities, avoiding overly broad or unnecessarily restrictive limitations.
  • Term and Renewal: Negotiate favourable renewal rights, including potential caps on annual price increases. Understand the terms for non-renewal or termination, including data destruction or retention obligations. Initiating renewal discussions well in advance, rather than waiting until the last minute, is advisable.
  • Audit Clauses: The specifics of CGS’s audit rights should be negotiated where possible, including the notice period for an audit, the authorisation of auditors, the tools and methods to be used, the scope of data to be provided, and mechanisms for dispute resolution.
  • Unbundling and Understanding Fee Drivers: If CUSIP services or data packages are presented as a bundle, firms should request itemised pricing to evaluate the cost and value of each component. A clear understanding of how the number of identifiers, business lines, and regions impacts the fee calculation is crucial for forecasting costs and identifying potential areas for optimisation.
  • Strategies for Mid-Size Firms: Mid-size firms, which may have less negotiating leverage than global institutions, should clearly articulate any limited scope of usage. While CGS licenses are typically individual, exploring whether any group negotiation avenues exist through industry associations could be beneficial, though unlikely to alter CGS’s direct licensing model. Demonstrating credible exploration or use of alternative identifiers might also subtly signal reduced dependency.
  • Vendor Communication Protocol: Establish a clear internal protocol defining who communicates with CGS during negotiations, their roles, and the information they are authorised to share. This ensures a consistent and strategic approach from the firm’s side.

 

The effectiveness of negotiations with CGS is often correlated with a firm’s ability to demonstrate a deep, documented understanding of its own CUSIP data usage and, critically, a credible awareness and willingness to explore alternatives, even if a full migration to another identifier system is complex and costly. A well-informed client, capable of challenging assumptions about their usage or demonstrating reduced reliance, is generally in a stronger negotiating position.

 

6.3. Leveraging Technology: Data Management Platforms and Identifier Translation

Technology can play a crucial role in managing CUSIP data more efficiently and mitigating associated costs.

  • Enterprise Security Master Platforms: Implementing or optimising robust security master solutions (such as those offered by GoldenSource or similar EDM platforms) can centralise the management of financial instrument reference data. These platforms are designed to handle multiple identifier types (CUSIP, ISIN, FIGI, proprietary IDs, etc.), manage incoming data feeds from various vendors, enforce data governance policies, and provide a consistent, validated source of security data to downstream systems.
  • Financial Data Aggregation Services: Utilising financial data aggregation platforms, like BridgeFT, can provide access to multi-custodial data through a normalised, standardised data model. Such platforms ingest data from numerous sources, potentially reducing a firm’s direct reliance on multiple individual vendor feeds that carry CUSIP data and their associated pass-through licensing complexities. The normalisation feature, by removing the “complexities and intricacies of each individual source”, can simplify data integration.
  • Identifier Translation and Mapping Tools: In an environment where multiple identifiers coexist, or during a transition phase, tools or internal capabilities for mapping and translating between CUSIP, FIGI, ISIN, and other identifiers become essential. While some public tools exist for basic conversion (e.g., ISIN.org’s CUSIP to ISIN tool, for educational purposes), enterprise-grade solutions often require more sophisticated internal development or commercial tools. Industry initiatives, like those explored by FINOS, also touch upon the conceptual mapping between various symbologies.
  • Data Bridge Platforms: For managing and analysing large datasets, platforms like WO Data Bridge can serve as gateways to business intelligence tools, potentially incorporating and helping to rationalise data from various sources, including those containing financial identifiers.

 

6.4. A Pragmatic Approach to Adopting Alternative Identifiers

While alternatives like FIGI offer the allure of “free” identifiers, a pragmatic and thorough assessment is crucial.

  • Feasibility and Total Cost of Ownership (TCO) Analysis: Before committing to a switch or significant supplementation with FIGI or ISIN, firms must conduct a comprehensive TCO analysis. This analysis must extend beyond the direct cost of the identifier itself (which for FIGI is zero) to include the substantial costs of data migration, system integration and re-engineering, process changes, staff training, and, critically, any potential loss of data richness or utility if relying solely on the free versions of these alternatives.
  • Assess Data Needs vs. Alternative Offerings: Firms must critically evaluate whether a “free” FIGI identifier, potentially accompanied by limited free metadata from OpenFIGI, meets all their business, risk, and compliance requirements. If subscriptions to richer commercial data sources (e.g., via Bloomberg for comprehensive FIGI-related data, or CGS for CUSIP-derived ISIN data) are still necessary to achieve the required level of data depth and quality, then some of the anticipated cost savings from moving away from CUSIP licenses may not materialise.
  • Phased Adoption and Coexistence: A “big bang” switch from CUSIP is often impractical and risky. A phased approach to adopting alternative identifiers, perhaps starting in specific, less critical business areas, for new instruments, or for particular use cases (like internal analytics where FIGI’s granularity might be beneficial), is generally more prudent. Firms should also develop robust strategies for managing a multi-identifier environment where CUSIPs, ISINs, and FIGIs are likely to coexist for a considerable period.

 

6.5. Industry Engagement and Staying Abreast of Change

The landscape of financial instrument identifiers is not static.

  • Monitor Regulatory Developments: Financial institutions must keep a close watch on regulatory discussions and rulemakings, particularly those stemming from initiatives like the Financial Data Transparency Act (FDTA) in the US Regulatory mandates or endorsements could significantly shift the balance between proprietary and open identifiers over time, although this is typically a slow process marked by considerable industry debate and lobbying.
  • Participate in Industry Initiatives: Engaging with industry associations (e.g., SIFMA, IAA) and standards bodies (e.g., FINOS, ANSI X9) that are working on open standards, data transparency, and solutions for financial identifiers can provide valuable insights and a voice in shaping future developments.
  • Advocate for Fairer Terms: Where possible, firms should support collective industry efforts to advocate for more transparent, non-discriminatory, and cost-effective licensing practices for essential market infrastructure identifiers like CUSIP.

 

Ultimately, true and sustainable cost mitigation for CUSIP licensing demands this holistic strategy. No single tactic—be it aggressive negotiation, technology deployment, or adoption of alternatives—is likely to be a silver bullet. It is the integrated application of these approaches that will yield the most significant results. As financial markets become increasingly data-driven and automated, the strategic management of financial identifiers and their associated licensing costs will evolve into an even more critical competitive differentiator. Firms that master this complex domain are poised to achieve superior operational efficiency and cost control.

7. Case Vignettes: The Real-World Impact of Identifier Licensing Costs

The following illustrative vignettes, based on challenges highlighted in the available research, demonstrate the tangible impact of CUSIP licensing costs and complexities on different types of financial institutions. While specific company names are not used due to the nature of the research material, these scenarios reflect common pain points.

 

Vignette 1: The Mid-Size European Asset Manager’s Dilemma

A European asset manager with a global investment mandate, including significant holdings in U.S. securities, finds itself ensnared in the complexities of CUSIP-derived U.S. ISIN licensing. The firm faces substantial costs, either through direct CGS licenses required for its European operations or via pass-through fees from its data vendors who are themselves CGS licensees. The manager struggles with restrictive use rights that hinder efforts to consolidate security data for pan-European portfolio analytics and regulatory reporting. 

Hidden costs manifest as inflated data vendor invoices, potentially duplicative licensing requirements for different legal entities or regions within their organisation, significant legal expenses for reviewing complex cross-border licensing agreements, and the operational overhead of mapping U.S. identifiers to their internal security master and downstream systems. In exploring mitigation, the firm has investigated using FIGI for its U.S. security identification needs but remains concerned about the completeness of freely available FIGI metadata for comprehensive risk management and compliance verification. Attempts to negotiate more favourable regional licensing terms with CGS or its distributors have yielded limited success due to the perceived lack of viable alternatives for authoritative U.S. security identification data.

 

Vignette 2: The Fintech Innovator’s Roadblock

A financial technology startup is developing a novel AI-driven portfolio analytics platform aimed at registered investment advisors (RIAs). To train its machine learning models effectively and provide comprehensive security coverage for its clients, the fintech requires access to a broad universe of CUSIPs and their rich associated descriptive data. 

However, the projected cost of a CUSIP license that would permit such broad data usage, including potential redistribution rights within their platform, proves to be prohibitively expensive for the early-stage company. The hidden costs for this innovator are substantial: a significant opportunity cost as they are unable to launch their full product vision; R&D expenditure diverted to attempting to work with limited, alternative, or less granular data sources; and potential legal risks if their data sourcing and usage are not impeccably compliant with various identifier licensing regimes. The startup is exploring launching with FIGI data initially but faces pushback from potential RIA clients who demand CUSIP-level granularity and are concerned about potential data gaps in the FIGI ecosystem for certain asset classes or descriptive fields. The fintech is also dedicating resources to lobby, often through industry consortiums, for more startup-friendly or tiered CUSIP licensing models that could foster innovation.

 

Vignette 3: The Regional Broker-Dealer’s Compliance Burden


A U.S. regional broker-dealer operates multiple distinct business lines, including retail brokerage, a small institutional trading desk, and an investment advisory arm. The firm finds it challenging and resource-intensive to accurately track and report its CUSIP usage across these varied lines of business for its annual CUSIP Use of Service Statement (UOSS). There is a constant fear that under-reporting actual usage could trigger a costly and disruptive CGS audit, potentially leading to significant penalties. 

Conversely, over-reporting usage to err on the side of caution inflates their already tight operational budgets. The hidden costs include excessive staff hours dedicated to meticulously tracking CUSIP data dissemination and consumption, fees paid to external consultants for advice on interpreting CUSIP licensing terms and completing the UOSS, and the potential for overpayment due to conservative (i.e., overly inclusive) usage declarations. To mitigate these burdens, the broker-dealer is investing in internal data governance tools to better monitor CUSIP data flows and is carefully reviewing its business line operations to determine if any segments qualify for lower CUSIP usage tiers or specific fee waivers.

These vignettes underscore a critical point: CUSIP licensing costs and complexities are not merely line-item expenses but act as strategic constraints that can dictate product development roadmaps, market entry decisions, and core operational priorities. This impact is often felt more acutely by firms that lack the extensive scale, dedicated legal teams, or substantial budgets of global banking institutions. The current CUSIP licensing paradigm, with its associated direct and hidden costs, may inadvertently favour larger, incumbent institutions that are better equipped to absorb these financial and operational burdens. This, in turn, could potentially hinder competition and slow the pace of innovation from smaller, more agile players within the broader financial ecosystem.

8. Conclusion: Charting a Course Through the Identifier Labyrinth Towards Cost Efficiency and Innovation

The Committee on Uniform Securities Identification Procedures (CUSIP) system is an entrenched and vital component of North American financial market infrastructure. However, as this report has detailed, the true cost of CUSIP licensing for financial institutions extends far beyond the direct fees for identifier assignment and data access. A complex web of hidden costs, spanning operational overheads, compliance burdens, legal and negotiation expenditures, and constraints on innovation, collectively imposes a significant financial and strategic toll.

Financial institutions can no longer afford a passive stance towards identifier licensing. Proactive, informed, and strategic management of CUSIP data and its associated licenses is essential for effective cost control, operational integrity, and maintaining competitive agility. This requires a diligent approach to internal data governance, a robust strategy for license negotiation, the intelligent application of technology, and a pragmatic evaluation of alternative identifier solutions.

The landscape of financial instrument identification is dynamic and subject to ongoing evolution. The persistent debates surrounding proprietary identifiers like CUSIP, the landmark legal challenges to their licensing models, and the continuous scrutiny from regulatory bodies in both the U.S. and Europe signal a market in flux. The rise of open-source alternatives such as the Financial Instrument Global Identifier (FIGI), alongside the enduring global importance of the International Securities Identification Number (ISIN), presents both opportunities and complexities. Legislative and regulatory initiatives, such as the Financial Data Transparency Act (FDTA) in the U.S., hold the potential to gradually reshape this landscape towards greater transparency and, possibly, more open standards, though this is recognised as a slow and contentious process involving significant industry debate.

The path forward for financial institutions involves charting a careful course through this identifier labyrinth. The future of financial instrument identification will likely involve a multi-identifier environment for the foreseeable future. The ideal of a single, global, open, and free identifier that comprehensively meets all market needs remains elusive, with each existing system presenting its own set of trade-offs. Consequently, mastering the management of this complex, heterogeneous environment—through sophisticated security mastering, data mapping, and translation capabilities—will be a key determinant of success.

This report urges financial institutions to:

  1. Critically Assess Current Strategies: Undertake a comprehensive review of existing financial instrument identifier strategies and dependencies.
  2. Quantify Total Costs: Make a concerted effort to identify and quantify the full spectrum of direct and hidden costs associated with CUSIP licensing.
  3. Vigorously Pursue Mitigation: Implement the multifaceted mitigation strategies outlined in this report, including optimising internal data usage, enhancing negotiation practices, leveraging enabling technologies, and realistically evaluating the role of alternative identifiers.
  4. Engage in Industry Dialogue: Actively participate in industry discussions and initiatives aimed at fostering a more equitable, transparent, and innovation-friendly future for financial instrument identification.

 

The “hidden costs” associated with proprietary financial identifiers are not merely a financial drain on individual firms; they represent a systemic inefficiency within the broader market. Addressing these challenges proactively can unlock significant value, reduce operational friction, and cultivate a more competitive and innovative financial services industry.

References

  1. CUSIP Number – Investor.gov, accessed on May 24, 2025, https://www.investor.gov/introduction-investing/investing-basics/glossary/cusip-number
  2. About CGS Identifiers – CUSIP Global Services, accessed on May 24, 2025, https://www.cusip.com/identifiers.html
  3. www.cusip.com, accessed on May 24, 2025, https://www.cusip.com/pdf/fact_sheet/CUSIP%20ACCESS.pdf
  4. Advocacy for Replacing CUSIP with FIGI for Filings under the Financial Data Transparency Act (FDTA) – SEC.gov, accessed on May 24, 2025, https://www.sec.gov/comments/s7-2024-05/s7202405-547855-1569682.pdf
  5. Proprietary Costs Of Financial Reporting, Country-Level Attributes, And Financial Statement Comparability – ScholarWorks@UTEP, accessed on May 24, 2025, https://scholarworks.utep.edu/cgi/viewcontent.cgi?article=3969&context=open_etd
  6. Proprietary Costs and the Disclosure of Information About Customers – ResearchGate, accessed on May 24, 2025, https://www.researchgate.net/publication/314836494_Proprietary_Costs_and_the_Disclosure_of_Information_About_Customers
  7. CUSIP Global Services, Scott J. Preiss – RIN 3064-AF96 – FDIC, accessed on May 24, 2025, https://www.fdic.gov/federal-register-publications/cusip-global-services-scott-j-preiss-rin-3064-af96
  8. www.cusip.com, accessed on May 24, 2025, https://www.cusip.com/pdf/FeesforCUSIPAssignment.pdf
  9. File Number 265-33: Setting the Record Straight on … – SEC.gov, accessed on May 24, 2025, https://www.sec.gov/comments/265-33/26533-261766.htm
  10. Comments on Financial Data Transparency Act Joint Data Standards Under the Financial Data Transparency Act of 2022, accessed on May 24, 2025, https://www.federalreserve.gov/apps/proposals/comments/FR-0000-0136-01-C19
  11. ipmall.law.unh.edu, accessed on May 24, 2025, https://ipmall.law.unh.edu/sites/default/files/hosted_resources/IP_handbook/ch11/ipHandbook-Ch%2011%2011%20Bobrowicz%20Licensing%20Check-list.pdf
  12. NON-REAL-TIME TRACE DATA AGREEMENT – finra, accessed on May 24, 2025, https://www.finra.org/sites/default/files/FINRA_Non-Real-Time_TRACE-Data-Agreement.pdf
  13. Disclaimer – ICE, accessed on May 24, 2025, https://www.ice.com/fixed-income-data-services/data-and-analytics/disclaimer
  14. Fintech in Europe: Promises and Threats, WP/20/241, November 2020, accessed on May 24, 2025, https://www.imf.org/-/media/Files/Publications/WP/2020/English/wpiea2020241-print-pdf.ashx
  15. www.federalreserve.gov, accessed on May 24, 2025, https://www.federalreserve.gov/apps/proposals/comments/FR-0000-0136-01-C148
  16. www.fdic.gov, accessed on May 24, 2025, https://www.fdic.gov/system/files/2024-09/2024-financial-data-transparency-act-3064-af96-c-001.pdf
  17. Financial Instrument Global Identifier – Wikipedia, accessed on May 24, 2025, https://en.wikipedia.org/wiki/Financial_Instrument_Global_Identifier
  18. OpenFIGI: Unlock the Power of Efficiency with Open Symbology, accessed on May 24, 2025, https://www.openfigi.com/
  19. Regulations – OpenFIGI, accessed on May 24, 2025, https://www.openfigi.com/about/regulations