ISIN User Group Issues Contract

1. ISIN User Group IssuesContract/ASB Enhancements ANNA General Meeting May 2002 • Athens, Greece Michael Atkin, FISD Thank you for inviting me to the meeting Introduce I think it’s important to note it was two years ago this month at the last ANNA meeting I attended in Cyprus. As I recall – the eventual outcome of that meeting was the creation of the ASB. A significant accomplishment in its own right I sincerely hope that the outcome of this meeting is as significant. Grateful for the invitation – and the opportunity to share some ideas with you about two things – the results of all the discussions that have taken place on the ASB contract and some thoughts about the future of the Service Bureau in what I will term – the Post-GIAM era.Thank you for inviting me to the meeting Introduce I think it’s important to note it was two years ago this month at the last ANNA meeting I attended in Cyprus. As I recall – the eventual outcome of that meeting was the creation of the ASB. A significant accomplishment in its own right I sincerely hope that the outcome of this meeting is as significant. Grateful for the invitation – and the opportunity to share some ideas with you about two things – the results of all the discussions that have taken place on the ASB contract and some thoughts about the future of the Service Bureau in what I will term – the Post-GIAM era.

2. ISIN User Group Issues Overall emphasis is on the increasing importance of securities numbering schemes in automated environments Two Core Issues ASB Contract (access and usage under reasonable terms and conditions) ASB Product Enhancement (unique and complete identification of all tradable instruments) A lot has happened over the past two years. Much of it driven by issues associated with efficiency, automation, T+1 and straight through processing. And security identification, ISIN and the ASB have been a key part of many of those discussions One of the primary themes I’d like to focus on -- one that gets validated in every discussion – is the increasing importance of security identification numbers in automated environments. Specifically, I’d like to do that as it relates to two issues The ASB Contract – with a concept that I hope plays well in Athens And the future role of the Service Bureau – now that the initial conversion from GIAM has been achievedA lot has happened over the past two years. Much of it driven by issues associated with efficiency, automation, T+1 and straight through processing. And security identification, ISIN and the ASB have been a key part of many of those discussions One of the primary themes I’d like to focus on -- one that gets validated in every discussion – is the increasing importance of security identification numbers in automated environments. Specifically, I’d like to do that as it relates to two issues The ASB Contract – with a concept that I hope plays well in Athens And the future role of the Service Bureau – now that the initial conversion from GIAM has been achieved

3. Three Cheers for ANNA Listened to the needs of the industry Quick understanding and response to inevitability of STP Fast track creation of ASB Partnership with industry through User Group Phase one improvements are evident! I would like to take a moment however to give credit where credit is due Phase one of the activity – from the first pitch 2 years ago to the success of the ASB as an operating entity has been terrific. The creation of the ISIN user group has helped with cross-industry understanding and has been effective You’ve achieved what you set out to accomplish – and that’s a wonderful thing. I would like to take a moment to offer you some perspective of how the industry views this activity. I would like to take a moment however to give credit where credit is due Phase one of the activity – from the first pitch 2 years ago to the success of the ASB as an operating entity has been terrific. The creation of the ISIN user group has helped with cross-industry understanding and has been effective You’ve achieved what you set out to accomplish – and that’s a wonderful thing. I would like to take a moment to offer you some perspective of how the industry views this activity.

4. Review of Specification Performance Issues – Phase One (assignment, maintenance, NNA compliance, timely dissemination) Access and Licensing Issues – Phase Two(centralized administration, promote redistribution, improve customer support) Product Specification – Phase Three (available prior to date of security issuance, contain all information required to precisely and uniquely identify the security) In order to do that, I went back to the original specifications developed by the ISIN User Group – vendors, user firms, SWIFT members, custodian banks and clearing organizations The first issue – what I’ll term Phase One -- was performance related. Issues related to new issue assignment, non-assignment of ISIN, multiple assignment, substitute numbers, compliance with the ISO standard and dissemination infrastructure. The second – or Phase Two – deals with the commercial terms. Reducing administrative burdens, improving customer service and creating a business model that promotes commerce. The goal is to make sure that the commercial structures allow for primary identification numbers to be used. The third – Phase Three – is about making sure the product contains all relevant information required to precisely and uniquely identify the financial instrument. At the end-of-the-day this is the most critical of all. This is the heart of the symbology requirement particularly as we move toward the efficiency of automation.In order to do that, I went back to the original specifications developed by the ISIN User Group – vendors, user firms, SWIFT members, custodian banks and clearing organizations The first issue – what I’ll term Phase One -- was performance related. Issues related to new issue assignment, non-assignment of ISIN, multiple assignment, substitute numbers, compliance with the ISO standard and dissemination infrastructure. The second – or Phase Two – deals with the commercial terms. Reducing administrative burdens, improving customer service and creating a business model that promotes commerce. The goal is to make sure that the commercial structures allow for primary identification numbers to be used. The third – Phase Three – is about making sure the product contains all relevant information required to precisely and uniquely identify the financial instrument. At the end-of-the-day this is the most critical of all. This is the heart of the symbology requirement particularly as we move toward the efficiency of automation.

5. Performance Issues The ASB is doing an effective job Assignment and maintenance issues are being managed Congratulations and thank you On Phase One – excellent job. Looks like you’re well on your way. No small feat. The industry is grateful. Congratulations are clearly in order to ANNA, S&P and Telekurs for what they’ve accomplished But doing GIAM better was not the extent of the specification. It was the first step down the path in a rapidly changing environment. We need to keep going! On Phase One – excellent job. Looks like you’re well on your way. No small feat. The industry is grateful. Congratulations are clearly in order to ANNA, S&P and Telekurs for what they’ve accomplished But doing GIAM better was not the extent of the specification. It was the first step down the path in a rapidly changing environment. We need to keep going!

6. ASB Contract Requirements Centralized administration to avoid complex/non-available bilateral agreements Modular uniform license with terms and conditions that promote commerce No re-licensing provisions on end-users Credits if direct service from NNA Centralized customer support to resolve data accuracy, technical and contract issues Here’s what emerged from the original specification as the request to the ASB on contractual issues Simplify administration Clarify NNA business requirements (which require a bilateral agreement, which are covered under the core agreement, which are unclear) – this is an important requirement and one where there is still some degree of confusion within the industry. The importance of pricing, data usage and commercial transparency The maintenance of a level playing field among all recipients of ISIN data And a clearing to discuss business models that simplify the acquisition, redistribution and usage of primary identifiers and support the objectives of T+1 and STP. In essence a commercial structure that supports business while continuing to protect the commercial requirements of the data originators So let’s take a look at where we are on these objectivesHere’s what emerged from the original specification as the request to the ASB on contractual issues Simplify administration Clarify NNA business requirements (which require a bilateral agreement, which are covered under the core agreement, which are unclear) – this is an important requirement and one where there is still some degree of confusion within the industry. The importance of pricing, data usage and commercial transparency The maintenance of a level playing field among all recipients of ISIN data And a clearing to discuss business models that simplify the acquisition, redistribution and usage of primary identifiers and support the objectives of T+1 and STP. In essence a commercial structure that supports business while continuing to protect the commercial requirements of the data originators So let’s take a look at where we are on these objectives

7. ASB Proposal Attempted to create one uniform license to obtain, use and redistribute ISIN information Mandates terms and conditions that are more restrictive than those already in place Vendors will not accept a global licensing solution to conflicts with existing agreements I fear that the vendors did not do as effective a job of communicating or prioritizing their requirements as they should have Because the message that the ASB heard was that there should be one uniform license to obtain, use and redistribute ISIN information And we of course realize how difficult a task that truly is. I see now why Scott has developed so many gray hairs for one so young. The result of the ASB effort was a contract that mandates terms that are more restrictive than those already in place and more restrictive than the bilateral agreements the vendors had with the individual NNA’s Bottom line is that the vendors won’t accept a global license that conflicts with existing agreements and definitely won’t sign a license that offers worse terms than they already have. I fear that the vendors did not do as effective a job of communicating or prioritizing their requirements as they should have Because the message that the ASB heard was that there should be one uniform license to obtain, use and redistribute ISIN information And we of course realize how difficult a task that truly is. I see now why Scott has developed so many gray hairs for one so young. The result of the ASB effort was a contract that mandates terms that are more restrictive than those already in place and more restrictive than the bilateral agreements the vendors had with the individual NNA’s Bottom line is that the vendors won’t accept a global license that conflicts with existing agreements and definitely won’t sign a license that offers worse terms than they already have.

8. ISIN User Group Proposal Modular license (core license with separate addenda for NNA’s that currently require additional licensing terms) Centralizes contract administration Terms and conditions as uniform as possible Creates foundation for ongoing discussion about business models and usage requirements Based on ISIN Data License Agreement plus core ANNA Agreement and LSE Securities Masterfile Agreement When the vendors got together with the ASB late last year to look over the initial proposal – they suggested a different approach If it’s impossible to come up with a single contract (as desirable as that is) – modular is the way to go. They asked us to create a modular approach that consisted of a core agreement and allows for the addition of separate addenda for the NNA’s that currently require (and wish to maintain) separate licensing terms So what we did was to start with the ISIN Data License that the ASB created and incorporated terms and conditions from the Core ANNA agreement already in place -- plus a few alternative terms and conditions from the London Stock Exchange’s Securities Masterfile License agreement. And while the vendors wanted a much different contract, they realized the value of basing the agreement on pre-existing contracts that were already in use in the marketplace. And that’s what they presented to the ASB It’s a modular agreement It centralizes contract administration It creates a uniform template And it provides a common starting point for ongoing discussions about business models and usage requirements When the vendors got together with the ASB late last year to look over the initial proposal – they suggested a different approach If it’s impossible to come up with a single contract (as desirable as that is) – modular is the way to go. They asked us to create a modular approach that consisted of a core agreement and allows for the addition of separate addenda for the NNA’s that currently require (and wish to maintain) separate licensing terms So what we did was to start with the ISIN Data License that the ASB created and incorporated terms and conditions from the Core ANNA agreement already in place -- plus a few alternative terms and conditions from the London Stock Exchange’s Securities Masterfile License agreement. And while the vendors wanted a much different contract, they realized the value of basing the agreement on pre-existing contracts that were already in use in the marketplace. And that’s what they presented to the ASB It’s a modular agreement It centralizes contract administration It creates a uniform template And it provides a common starting point for ongoing discussions about business models and usage requirements

9. Our Suggestion The modular contract concept is acceptable to the vendors The modular contract concept has the support of S&P, Telekurs and the ASB Chair Continue the dialogue on business models that simplifies the acquisition, redistribution and usage of primary identification numbers Adoption by ANNA members is required to move to the next step The contract is acceptable to the vendors in concept The contract is acceptable to the ASB operators in concept I’m sure that the lawyers for S&P and Telekurs are reviewing the agreement with a fine tooth comb It is our sincere hope that the approach will be acceptable to the ANNA membership so that everyone can move forward I think the next steps and the procedural management of this issue is in the hands of Mr. Kuhnel (yes). I’d be more than happy to take questions – if there are any – before switching gears and talking about the potential role of the ASB in the next phase of its operation.The contract is acceptable to the vendors in concept The contract is acceptable to the ASB operators in concept I’m sure that the lawyers for S&P and Telekurs are reviewing the agreement with a fine tooth comb It is our sincere hope that the approach will be acceptable to the ANNA membership so that everyone can move forward I think the next steps and the procedural management of this issue is in the hands of Mr. Kuhnel (yes). I’d be more than happy to take questions – if there are any – before switching gears and talking about the potential role of the ASB in the next phase of its operation.

10. ANNA Service Bureauin the Post-GIAM Era Meeting the Symbology Requirements of Automation

11. ASB Mission (industry view) Work with ANNA members to improve ISIN assignment, maintenance and usability Manage the dissemination process and ensure timely access to primary identifiers Ensure that all financial instruments (that are issued and tradable) have an ISIN Ensure that ASB Feed contains ALL relevant information required to uniquely and precisely identify the instrument Over the past two years, there has been a lot of discussions about symbology and the requirements for unique and precise instrument identification. The discussion has spawned the FISD research on security identification and led to our conclusions about place of listing identifiers, register level identifiers and other cross-linkage requirements The role and function of both ISIN (the 6166 standard) and the role and function of the ASB is always at the core of these discussions. In many ways it boils down to a definition of the mission of the Service Bureau. The industry has its thoughts on mission. The ANNA members likely have theirs, and the ASB likely has its. I honestly believe this is one of the core issues to get resolved. Perhaps the ASB is a partner with the industry in trying to address some of the issues related to automation – perhaps it isn’t. The potential is clearly there. ISIN as well as local identifiers are important and fundamental. And regardless of how and where the solution emerges, it will likely have some very close relationship with ISIN and the ASB. So I’d like to give you a summary of what the industry (outside of the NNA’s) view as the mission – or perhaps the fantasy mission -- of the ASB. And I think it consists of four principles: First is to address the issues associated with ISIN timeliness, accuracy, usability and maintenance. I don’t think there is any debate here. Core function and core competency of the ASB. Second is to manage the dissemination process. Again, no debate. Third is to ensure complete coverage. I think the ASB, ANNA and the industry are all in agreement. The challenges here are not based on orientation or desire – but rather on commercial issues and implementation obstacles Finally – and this is the biggie – to ensure that the ASB feed contains all relevant information required to uniquely and precisely identify financial instruments. At the end-of-the-day ANNA and the ASB might reject this objective. We hope you don’t. And if you do, the industry will have to assess its options and look for alternative strategies to accomplish their objectives and meet their requirements. What I’d like to do if try to make the case why principle number four is so important and why the ASB is in a perfect position to help move these specification requirements forward.Over the past two years, there has been a lot of discussions about symbology and the requirements for unique and precise instrument identification. The discussion has spawned the FISD research on security identification and led to our conclusions about place of listing identifiers, register level identifiers and other cross-linkage requirements The role and function of both ISIN (the 6166 standard) and the role and function of the ASB is always at the core of these discussions. In many ways it boils down to a definition of the mission of the Service Bureau. The industry has its thoughts on mission. The ANNA members likely have theirs, and the ASB likely has its. I honestly believe this is one of the core issues to get resolved. Perhaps the ASB is a partner with the industry in trying to address some of the issues related to automation – perhaps it isn’t. The potential is clearly there. ISIN as well as local identifiers are important and fundamental. And regardless of how and where the solution emerges, it will likely have some very close relationship with ISIN and the ASB. So I’d like to give you a summary of what the industry (outside of the NNA’s) view as the mission – or perhaps the fantasy mission -- of the ASB. And I think it consists of four principles: First is to address the issues associated with ISIN timeliness, accuracy, usability and maintenance. I don’t think there is any debate here. Core function and core competency of the ASB. Second is to manage the dissemination process. Again, no debate. Third is to ensure complete coverage. I think the ASB, ANNA and the industry are all in agreement. The challenges here are not based on orientation or desire – but rather on commercial issues and implementation obstacles Finally – and this is the biggie – to ensure that the ASB feed contains all relevant information required to uniquely and precisely identify financial instruments. At the end-of-the-day ANNA and the ASB might reject this objective. We hope you don’t. And if you do, the industry will have to assess its options and look for alternative strategies to accomplish their objectives and meet their requirements. What I’d like to do if try to make the case why principle number four is so important and why the ASB is in a perfect position to help move these specification requirements forward.

12. Symbology Issues are Core Automation (in a complex world) requires precision Reference data maintenance is still mostly a manual process Bad reference data is a significant cause of trade failures Reference data standards are a key to STP automation As we all know, the world is getting more complex. Global trading. Multiple listings. Interrelated trading platforms. Complex settlement requirements. We could go on and on. The simple truth is that financial instruments can be issued, priced, traded and settled in many ways. As such different types of identifiers are relevant at various levels and are used to convey information about the market on which the security is listed, the clearing systems through which the trade will clear, the CSD where the trade will settle and the register to record changes in security ownership. Most of this complexity gets handled within back office operations. And a lot of it is manual. The reference data challenges facing the industry are immense. Manual processes require significant resources and are the enemies of automation and risk management. Bad reference data is the leading cause of internal STP failures and poses the single greatest challenge to STP. To be interpreted correctly by a machine, each element of reference data requires a unique business definition that must be represented in standard code. The relationship between a code and its corresponding business meaning must be maintained, stored and retrieved from a database. Business interpretation must be consistent. Reference data is a lot more complicated than transactional information that just needs to be passed from one application to the next. Reference data needs to be maintained. Errors in reference data have implications to future transactions. Reference data affects every application – from measuring exposure to counterparties, to calculating portfolio values, to assessing compliance to supporting investment decisions to routing instructions to the proper destinationAs we all know, the world is getting more complex. Global trading. Multiple listings. Interrelated trading platforms. Complex settlement requirements. We could go on and on. The simple truth is that financial instruments can be issued, priced, traded and settled in many ways. As such different types of identifiers are relevant at various levels and are used to convey information about the market on which the security is listed, the clearing systems through which the trade will clear, the CSD where the trade will settle and the register to record changes in security ownership. Most of this complexity gets handled within back office operations. And a lot of it is manual. The reference data challenges facing the industry are immense. Manual processes require significant resources and are the enemies of automation and risk management. Bad reference data is the leading cause of internal STP failures and poses the single greatest challenge to STP. To be interpreted correctly by a machine, each element of reference data requires a unique business definition that must be represented in standard code. The relationship between a code and its corresponding business meaning must be maintained, stored and retrieved from a database. Business interpretation must be consistent. Reference data is a lot more complicated than transactional information that just needs to be passed from one application to the next. Reference data needs to be maintained. Errors in reference data have implications to future transactions. Reference data affects every application – from measuring exposure to counterparties, to calculating portfolio values, to assessing compliance to supporting investment decisions to routing instructions to the proper destination

13. Reference Data Quality A precise instrument identification scheme is needed to eliminate inefficiencies and help mitigate the risks of trade failure The world is getting more complex … time is becoming compressed … the risks are getting greater Primary identification numbers (ISIN) are key to many aspects of reference data quality Incorrect security codes can lead to more exceptions and the risk of failing to settle trades on contractual settlement date. An even greater risk is the likelihood of calculating the net asset value of a mutual fund incorrectly based on an erroneous security identifier. Inaccurate reference data is the cause of over ½ of the trade failures within some organizations. And the world is getting more complex.Incorrect security codes can lead to more exceptions and the risk of failing to settle trades on contractual settlement date. An even greater risk is the likelihood of calculating the net asset value of a mutual fund incorrectly based on an erroneous security identifier. Inaccurate reference data is the cause of over ½ of the trade failures within some organizations. And the world is getting more complex.

14. Reference Data Components Asset identification (ISIN+) Account identification Counterparty identification (links to ISIN) Settlement instructions (OPOL/Register) Descriptive data (security master file links to ISIN) Generic data Fee/tax/commission rates Now, of course, not all of this problem relates to security identifiers. In fact counterparty identifiers are way more problematic. But security identifiers are a big component. And linkages between issues, legal entities and security identification is critical. That’s why the entire back office is moving toward standards. And everyone prefers industry-accepted standards wherever possible. Just look around at what’s happening right now with the standards developments at SWIFT and ISO 15022 data dictionary. Complete transparency. The critical importance of defining common vocabularies. The move to define the meaning of data. The whole motivation behind XML. This is the environment into which the industry is moving. Now, of course, not all of this problem relates to security identifiers. In fact counterparty identifiers are way more problematic. But security identifiers are a big component. And linkages between issues, legal entities and security identification is critical. That’s why the entire back office is moving toward standards. And everyone prefers industry-accepted standards wherever possible. Just look around at what’s happening right now with the standards developments at SWIFT and ISO 15022 data dictionary. Complete transparency. The critical importance of defining common vocabularies. The move to define the meaning of data. The whole motivation behind XML. This is the environment into which the industry is moving.

15. The Role of the ASB? Unique security identification requirements are complex and evolving Official place of listing Register level identifiers Other data elements (CFI +) Linkage requirements between ISIN and other components of reference data are still evolving Links between legal entities, issues and ISIN Which brings us back to the core question of the role of the ASB. The importance of ISIN and the position of the ASB are very important to the industry. And that’s why our members have been spending so much energy dealing with issues such as official place of listing and register level identifiers, and business entity identifiers, and counterparty identifiers and our own XML standard called MDDL (market data definition language) And I can almost guarantee you that this is just the beginning. We are in an evolutionary moment in our industry. The requirements of automation are still being formed. Answers are not simple. But there is no stopping the process. Automation is being driven by the twin demands of efficiency and risk mitigation. Automation will happen – someway or another. Which brings us back to the core question of the role of the ASB. The importance of ISIN and the position of the ASB are very important to the industry. And that’s why our members have been spending so much energy dealing with issues such as official place of listing and register level identifiers, and business entity identifiers, and counterparty identifiers and our own XML standard called MDDL (market data definition language) And I can almost guarantee you that this is just the beginning. We are in an evolutionary moment in our industry. The requirements of automation are still being formed. Answers are not simple. But there is no stopping the process. Automation is being driven by the twin demands of efficiency and risk mitigation. Automation will happen – someway or another.

16. Role of the ASB? Unclear, but potentially significant Interactive dialogue between industry and ASB is required as issues evolve Timely decision-making from ASB has an impact on requirements Are requests feasible? Is ASB capable? Are commercial terms acceptable? So, therefore, what is the role of the ASB in this evolution. To be honest – I don’t fully know. No one fully knows. We have our suspicions. And I’m sure many of them are wrong and that there will be many iterations before the industry finds its way But, I do know that this difficult path will be easier if the ASB was a partner with the rest of the industry in trying to figure out these issues. And by partner, I mean able to freely engage in the ongoing dialogue and able to make timely decisions about requests for service enhancements. Are these request feasible? Is the ASB capable of providing what’s being requested? Are there commercial implications? So, therefore, what is the role of the ASB in this evolution. To be honest – I don’t fully know. No one fully knows. We have our suspicions. And I’m sure many of them are wrong and that there will be many iterations before the industry finds its way But, I do know that this difficult path will be easier if the ASB was a partner with the rest of the industry in trying to figure out these issues. And by partner, I mean able to freely engage in the ongoing dialogue and able to make timely decisions about requests for service enhancements. Are these request feasible? Is the ASB capable of providing what’s being requested? Are there commercial implications?

17. Two Sides of the Equation Input Side Primary relationship is between the ASB and NNA’s (through ANNA) ISO 6166 and ANNA Guidelines Output Side Primary relationship is between the ASB and the industry ISIN plus additional data elements required for unique and precise identification So as I was thinking about this issue it struck me that there were two sides of the ASB/ANNA equation First there is the input side. This is a relationship between the ASB and the NNA’s and ANNA. This is about the ISO 6166 standard and the ANNA Guidelines. This is about the business of numbering. This is the input side of the ASB. We all know, this is your core business. And from what I can tell, this is not an issue for the rest of the industry to be involved in. On the other side is the output of the ASB. This is a relationship between the ASB and the industry – vendors, trading firms, custodians, settlement agencies, STP solutions, etc. The industry needs more than just ISIN. They need all the additional data elements required for unique and precise identification. So as I was thinking about this issue it struck me that there were two sides of the ASB/ANNA equation First there is the input side. This is a relationship between the ASB and the NNA’s and ANNA. This is about the ISO 6166 standard and the ANNA Guidelines. This is about the business of numbering. This is the input side of the ASB. We all know, this is your core business. And from what I can tell, this is not an issue for the rest of the industry to be involved in. On the other side is the output of the ASB. This is a relationship between the ASB and the industry – vendors, trading firms, custodians, settlement agencies, STP solutions, etc. The industry needs more than just ISIN. They need all the additional data elements required for unique and precise identification.

18. ASB Decision-Making OPOL Illustration Requirement validated by FISD research Understandable that NNA’s might not have access to secondary/tertiary listings ASB might be in a position to collect, link and disseminate listing data (there will be others) And it occurred to me that perhaps we’re making the wrong pitch to the numbering agencies. And the situation with Official Place of Listing is a perfect illustration. We did a significant amount of research on the requirements for unique security identification. We talked to all sides of the industry and looked at what each segment did and what it needed. I feel confident that our research has been validated. The mistake we made was the failure – on our part -- to make a distinction between making a request of the ASB and making a request of the numbering agencies. It is absolutely understandable that the NNA’s – if not exchanges – would not have access to secondary and tertiary listings. Your response from your last meeting is perfectly understandable. Of course -- it is completely unfair to ask NNA’s to provide information they don’t have. Something got lost in the translation. We thought we were making a request of the ASB. And we thought the ASB might be in a position to collect, link and disseminate listing data. And it occurred to me that perhaps we’re making the wrong pitch to the numbering agencies. And the situation with Official Place of Listing is a perfect illustration. We did a significant amount of research on the requirements for unique security identification. We talked to all sides of the industry and looked at what each segment did and what it needed. I feel confident that our research has been validated. The mistake we made was the failure – on our part -- to make a distinction between making a request of the ASB and making a request of the numbering agencies. It is absolutely understandable that the NNA’s – if not exchanges – would not have access to secondary and tertiary listings. Your response from your last meeting is perfectly understandable. Of course -- it is completely unfair to ask NNA’s to provide information they don’t have. Something got lost in the translation. We thought we were making a request of the ASB. And we thought the ASB might be in a position to collect, link and disseminate listing data.

19. What is the ASB Mission? GIAM (better) or industry utility to meet automation objectives? The industry sees an enhanced role for the ASB Is this a reasonable path to pursue? Can the ASB be empowered to assess and make output side decisions without ANNA approval? We didn’t realize that the ASB was not empowered to entertain these types of requests. I feel very foolish for not understanding that – but now that I do, I think we can get right down to the core of this activity. And it comes back to the question about the mission and function of the ASB Is it to be the central collection and dissemination point for ISIN data. In essence just to improve what ANNA had been doing with GIAM or can it be as a utility to help the industry meet its automation objectives. I hope I’ve made it completely clear that the industry would like the latter. They see an enhanced role for the ASB. The core question I’d like to put on your table is whether this is a reasonable path for the industry to pursue? Can the ASB be empowered to assess and make output side decisions? Can the ASB become a full participant in these industry discussions? Is this an activity worth pursuing or should we look at other options. We didn’t realize that the ASB was not empowered to entertain these types of requests. I feel very foolish for not understanding that – but now that I do, I think we can get right down to the core of this activity. And it comes back to the question about the mission and function of the ASB Is it to be the central collection and dissemination point for ISIN data. In essence just to improve what ANNA had been doing with GIAM or can it be as a utility to help the industry meet its automation objectives. I hope I’ve made it completely clear that the industry would like the latter. They see an enhanced role for the ASB. The core question I’d like to put on your table is whether this is a reasonable path for the industry to pursue? Can the ASB be empowered to assess and make output side decisions? Can the ASB become a full participant in these industry discussions? Is this an activity worth pursuing or should we look at other options.

20. Thank You Michael Atkin Financial Information Services Division Software & Information Industry Association 202.789.4450 matkin@siia.net www.fisd.net I am grateful for your time. I am grateful for your invitation to this meeting And I thank you for this opportunity.I am grateful for your time. I am grateful for your invitation to this meeting And I thank you for this opportunity.