Response to consultation on Draft Recommendation on the use of Legal Entity Identifier (LEI)

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Please, provide your feedback on the proposed timeline and the proposal of having less tight deadlines for banks not included in the EBA sample.

Still clarification is necessary on the timeline for LEI implantation. A prior approach was based upon the timeline of each regulation, where reporting using LEI was necessary: EMIR (February 2014), DFA, AIFM, and CCR.
But here two new timelines (31 March 2014 and 31 December 2014) are suggested, not for reporting but also for the competent authorities to verify if concerned institutions have obtained pre-LEI codes.
It enlarges the initial LEI perimeters, first initiated for regulatory reporting to a wide scoop of regulator reportings, not formerly identified. This creates some uncertainty and pressure upon the timelines which can be counterproductive vis-à-vis the LEI purposes.
Reconciling and coherence are prerequisites for a better introduction of the LEI.

Setting a unique deadline for December 2014, for instance, could secure opportunely the performance of the Global LEI System.

Also the latest deadline concerns “other institutions” which is not a clear category, does it covers asset managers or corporates?

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