# OFR FSI Rights Clarification — Submission Copy

Status: PREPARED／NOT SENT

## Subject

Rights and data clarification request — use of the OFR Financial Stress Index for an ASSET SHIFT derived research classification

## Message

Hello,

We are developing ASSET SHIFT, an unincorporated, individual-led research project in Japan. ASSET SHIFT is a public research dashboard for individual investors that presents medium- and long-term current-state classifications for six asset categories.

ASSET SHIFT is not a trading-signal service. It does not issue buy, sell, trading, or asset-allocation instructions. Its purpose is to organize official economic data and present the current environment while leaving all decisions to the user.

For a possible new version of the Cash component, we are evaluating the Office of Financial Research Financial Stress Index (OFR FSI). We understand that the OFR FSI is a daily market-based measure of systemic stress in global financial markets, is published with data current through two business days prior, and is constructed from 33 financial-market variables.

The OFR FSI indicators page identifies a number of third-party indexes and benchmarks and states that the source series are pulled from Datastream by Refinitiv. We therefore do not want to assume that the general copyright status of federal government works resolves the rights applicable to the aggregate OFR FSI data or our proposed use.

Our proposed workflow would not display, redistribute, or permit reconstruction of the underlying OFR FSI observations, constituent series, historical table, or downloaded Raw file. Subject to written permission, public users would see only a materially derived, non-price Cash classification, such as “Attractive,” “Neutral,” “Watch,” or “Unknown,” together with methodology, coverage, and audit metadata.

Could you please provide a written response to each of the following points?

1. May we download and use the official aggregate OFR FSI observations for internal research, model development, reproducibility testing, Backtest, untouched out-of-sample testing, and prospective Forward Validation?
2. May we retain exact, timestamped copies of downloaded OFR FSI files internally, together with retrieval metadata and SHA-256 checksums, including superseded Vintages after later corrections or revisions?
3. May a free public Research Preview display only a materially derived, non-reconstructable Cash classification and explanatory metadata, without displaying or redistributing the underlying OFR FSI observations, history, constituent data, or Raw files?
4. May the same materially derived classification be displayed in an advertising-supported, subscription-based, or otherwise commercial service?
5. Does use of the published aggregate OFR FSI output require permission from Refinitiv or any constituent index or benchmark provider? If so, could you identify the relevant rights holder and licensing route?
6. What exact attribution, source notice, disclaimer, and restrictions concerning OFR or Treasury names, seals, or implied endorsement would apply to internal research, free derived display, and commercial derived display?
7. What are the authoritative file name, stable download route, format, column names, date convention, time zone, missing-value encoding, coverage start, publication timing, and update schedule for the official downloadable OFR FSI data?
8. When the OFR corrects historical observations or changes the methodology, is the full backfile restated? How are release identity, correction date, affected observations, methodology version, and revision history recorded?

Please distinguish clearly between internal research use, internal Raw/Vintage retention, free derived public display, and commercial derived public display.

If this request should be handled by the OFR Financial Stress Index data owner, the Office of the Chief Counsel, or another authorized office, we would appreciate it if you could forward this message or identify the appropriate contact.

Until these matters are resolved in writing, ASSET SHIFT will not download the OFR FSI Raw data, execute the candidate Transform, inspect model results, select the candidate, or publicly emit a Cash classification derived from it.

Thank you for your assistance.

Regards,

ASSET SHIFT  
Name: Naoyasu Saitou  
Legal status: Unincorporated individual research project  
Country: Japan