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.

We deem the timelines indicated (March 31 and December 31) to be realistic for the introduction.
There are already sufficient pre-LOUs active and it is likely that more pre-LOUs would be appointed and start allocation in the coming weeks and months.
Finally it is most likely that already before the start of EMIR reporting on Feb 12, 2014 nearly all financial institutions would have a pre-LEI.

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