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Will an EU interim identifier be available in time for EMIR reporting?

The newly formed LEI ‘Regulatory Oversight Committee’ (ROC) has released its first progress note. In the time between its formation, the election of members and the handover from the Financial Stability Board (FSB) in January this year, the ROC has been making significant progress.

The newly formed LEI ‘Regulatory Oversight Committee’ (ROC) has released its first progress note. In the time between its formation, the election of members and the handover from the Financial Stability Board (FSB) in January this year, the ROC has been making significant progress.

The ROC has finally, formally recognised the process for the issuance of LEI compatible interim identifiers or ‘pre-LEIs’ through pre-Local Operating Units (LOUs) if they meet a certain set of requirements:

  • The pre-LOU complies with all FSB recommendations regarding the LEI
  • The pre-LOU only accepts self-registration
  • The pre-LOU should verify that the pre-LEI to be issued is not a duplicate and is unique to that entity
  • The pre-LOU ensures portability i.e. transferability to other pre-LOUs to avoid duplication of issued codes
  • The pre-LOU is sponsored by a ROC member
  • The local regulator/authority has confirmed with the ROC that the pre-LOU meets the above

Given that the industry in Europe is screaming for an interim identifier for the implementation of trade reporting under EMIR, this is good news. However, it remains to be seen just what impact these multiple LOUs and their codes will have on the stability of the LEI itself. It is obvious that the industry can’t wait too long for the final LEI to be finished.

Whilst, the ROC has endorsed the accounting consolidation approach as a first step for development of the LEI relationship data, there is still much work to be done and consensus to be built. The Central Operating Unit (COU), which will operationally govern the LEI, has only just been agreed to exist (in theory) as a foundation in Switzerland.

The private sector preparatory group (PSPG, of which JWG is a member) continues under the ROC to be hard at work designing solutions for the LEI, but we’ll have to wait and see which ones are adopted by the ROC and when.

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