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Global Legal Entity Identifier Initiative

Global Legal Entity Identifier Initiative. Data Services. Dan Thieke ACSDA Senior Summit – December 6, 2013. Controlled – Non-Confidential. LEI Key Public Policy Objective.

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Global Legal Entity Identifier Initiative

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  1. Global Legal Entity Identifier Initiative Data Services Dan Thieke ACSDA Senior Summit – December 6, 2013 Controlled – Non-Confidential

  2. LEI Key Public Policy Objective Strengthen systemic risk capabilities of regulators to analyze positions and transactions of firms they oversee on a globally integrated basis

  3. New Acronyms (like any good project) • GLEIS: Global LEI System • ROC: Regulatory Oversight Committee • GLEIF: Global LEI Foundation • COU: Central Operating Unit • LOU: Local Operating Units • ISO 17442: The Standard • CICI: CFTC Interim Compliant Identifier • GEI: General Entity Identifier (Europe) 3

  4. LEI Must Be Standardized Globally The LEI is a single unique 20-character alphanumeric code that is assigned to all entities that are counterparties to financial transactions and listed in an open database, available to all as a public good. The FSB and ROC have endorsed and adopted ISO Standard 17442. • Legal Name – Nestle SA • Address – Avenue Nestle 55, Vevey, Vaud 1800, Switzerland • Country of formation – Switzerland • Business Registry name and number • Entity Status – Active • Legal Form – Societe Anonyme • Dates of first assignment, last update • Date and reason for expiry KY37LUS27QQX7BB93L28 4

  5. Global Regulatory Community LEI Initiative  FSB delivered initial recommendations to G20 in June 2012.  FSB transitioned its responsibilities to the Regulatory Oversight Committee (ROC) in January 2013. The ROC adopted the FSB principles. • In March 2013, ROC set out criteria for issuance of the pre-LEI identifiers that could provide an interim solution for the establishment of the Global LEI System consistent with FSB LEI principles. • In October 2013, the ROC announced its first three globally endorsed LOUs, including DTCC’s CICI Utility.

  6. Regulatory Initiatives - Europe/North America Commodities Futures Trade Commission (CFTC) Swap Recordkeeping and Reporting Rule (Part 45) • All swap counterparties subject to CFTC jurisdiction must have a CICI • Deadline was April 10, 2013 EMIR (December 19, 2012) • Reporting on February 12, 2014 Securities and Exchange Commission (SEC) – Investment Advisors • On October 31, 2011 the SEC adopted new reporting requirements for certain advisers to hedge funds and other private funds. SEC-registered investment advisers with $150mm in private fund assets under management must file a new form (Form PF) with the SEC Canadian Securities Regulators – Consultation on Rules Relating to Derivatives (December 2012) • Proposes that all counterparties to transactions be identified by a legal entity identifier. It is envisioned that this identifier be a Legal Entity Identifier (LEI) from the Global LEI System

  7. CICI Utility Operational Principles • Global • Can support reporting across all jurisdictions and asset classes • Can easily support federation of registration, data maintenance, validation • Extensive global industry input to shape solution • Public good • Cost recovery model • Free and unrestricted access • Control • Built to deliver ISO 17442 standard • High quality data is a key focus • Utility strength infrastructure • Expertise • Over ten years of data validation expertise through Avox • Database already houses over 75,000 ISO-compliant LEIs

  8. CICI Utility Functionality  Registration  Self-registration  Assisted registration  Web vs. Bulk file registration  Number Assignment  SWIFT assignment of ISO 17442 standard  “5493” prefix beginning end of November  90,000 CICIs are now globally accepted  Validation  All registrations validated against publicly available sources  Result of validation published  Publication  Free full and delta files published daily  Free internet search  Data Quality/Maintenance (Avox processes)  Public challenge process  Annual re-certification  Refresh at least annually

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