Sources cited in the Bond Buyer’s March 10 article, “Interesting Times for BDA’s Boss,” make a a number of critical errors and misrepresentations in their references to CUSIP Global Services. 
In describing the Bond Dealers of America’s long-running efforts to avoid paying licensing fees for access to CUSIP Global Services’ institutional data feeds, the article distorts the history of our data licensing practice, misstates fee ranges, ignores our transparent disclosure on licensing fee calculation and makes erroneous reference to a European Commission investigation.

CUSIP Licensing Fee History
With respect to the article’s incorrect statement that CUSIP licensing fees were introduced in the mid-1990s, fees for access to bulk format data provided to institutional investors were part of the original charter to create the CUSIP identification system in 1968. The mid-90s are significant because that is when CUSIP Global Services started enforcing its licensing fees more aggressively to address the rise of data piracy stemming from the widespread growth of digital data transfer in the financial markets. 

CUSIP Fee Structure
The article also inflates the price range of fees charged to mid-market firms and claims that CUSIP Global Services “provides no insight into how it calculates fees.” In fact, CUSIP Global Services offers a number of services to the marketplace, ranging from free code look-ups and validation services to more robust institutional data feeds. It is explained clearly on our website — https://www.cusip.com/cusip/cgs-license-fees.htm#cgs-licensing-policies-faqs — that licensing fees for these data feeds are based on a firm’s data usage. This is in accordance with data provider industry norms. In order to provide fee transparency, we also provide a fee calculator — https://www.cusip.com/cusip/cgs-license-fees.htm — that allows firms to determine what their licensing fees would be before they become a customer.

European Commission
The Bond Buyer story also makes an erroneous reference to a European Commission investigation. CUSIP Global Services has been involved in ongoing discussion with the European Commission regarding ISIN licensing practices within Europe. The ISIN is the twelve digit international security identifier that is recognized by the International Standards Organization. The inquiry is not about CUSIP identifiers or our licensing practices regarding CUSIP identifiers. 

The Value Behind CUSIP
The true value of the CUSIP Global Services data feed is its efficiency and accuracy. Every security that receives a CUSIP ID is examined by a team of experienced analysts to ensure that each attribute — company, municipality, asset type — is clearly and accurately captured in the CUSIP database. This level of scrutiny ensures that each trade executed using a CUSIP ID is cleared instantly, and our data feed products ensure that financial institutions of every size and type are able to access our robust databases, whether directly from CUSIP Global Services or through an approved distributor, in a uniform and fully interoperable format. 

Had we been contacted by The Bond Buyer for comment prior to the article’s publication, we would have informed the reporter of the points above. 

Sincerely,

James D. Taylor
Managing Director
Head of CUSIP Global Services