Reporting for Legal Entity Identifiers

On March 16, the Federal Reserve Board (FRB) issued a proposal seeking public comment within 60 days that would require all banking organizations with existing Legal Entity Identifiers (LEIs) to report their respective LEIs on regulatory reporting forms beginning June 30, 2015.  Specifically the report ask for comments on: (a.) Whether the proposed collection of information is necessary for the proper performance of the Federal Reserve’s functions; including whether the information has practical utility; (b.) The accuracy of the Federal Reserve’s estimate of the burden of the proposed information collection, including the validity of the methodology and assumptions used; (c.) Ways to enhance the quality, utility, and clarity of the information to be collected; (d.) Ways to minimize the burden of information collection on respondents, including through the use of automated collection techniques or other forms of information technology; and (e.) Estimates of capital or start up costs and costs of operation, maintenance, and purchase of services to provide information.

Several years ago, the Financial Stability Board began implementing a global identifier system that would uniquely identify parties to financial transactions, and in January 2013, the LEI Regulatory Oversight Committee was established to oversee the Global Legal Entity Identifier System. As the usage of LEI becomes more prominent, it should enable examiners, economists, and financial analysts to perform improved analyses, particularly during stressed market conditions, and would assist the regulatory community and the financial services industry at large. In addition, it is expected that the use of the LEI among the regulators will expand to facilitate better information sharing and coordination regarding financial policy, rulemaking, examinations, reporting requirements, and enforcement actions.

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