Response to consultation on Draft Recommendation on the use of Legal Entity Identifier (LEI)
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The use of the LEI within other regulatory reporting, especially existing reporting, would likely take longer to integrate. However, this is an implementation matter and does not prevent EBA from adopting the use of LEIs for ITS immediately. Migration of industry and authorities to the full implementation of GLEIS standards, including but not limited to the LEI, will be a market-driven effort which will take many years to come. It will enable a joint learning experience for industry and authorities and will improve the system. The GLEIS will provide a central point where the market knows where to converge to on reference data matters. Legacy standards both regulatory and market based will coexist with LEI for a certain time, yet the wish is that the GLEIS will offer mapping to the new standard. Ultimately, adoption eases with penetration of LEI across all regulatory reporting schemes and the incentives to use LEI become stronger for every firm and the market as a whole.
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 support the proposed timeframes outlined in the Consultation. The process for obtaining a LEI is simple. Registration only takes a few minutes and (pre)-LEIs are issued within a few business days. There are now five endorsed LOUs and there are likely more to come in the near future, making local service for obtaining a (pre) LEI in Europe quite easy. All LEIs issued by these endorsed LOUs are eligible for reporting to all regulators that have assented to the ROC charter. This “mutual acceptance” of LEIs ensures that a single, unique and persistent LEI is assigned to each legal entity.The use of the LEI within other regulatory reporting, especially existing reporting, would likely take longer to integrate. However, this is an implementation matter and does not prevent EBA from adopting the use of LEIs for ITS immediately. Migration of industry and authorities to the full implementation of GLEIS standards, including but not limited to the LEI, will be a market-driven effort which will take many years to come. It will enable a joint learning experience for industry and authorities and will improve the system. The GLEIS will provide a central point where the market knows where to converge to on reference data matters. Legacy standards both regulatory and market based will coexist with LEI for a certain time, yet the wish is that the GLEIS will offer mapping to the new standard. Ultimately, adoption eases with penetration of LEI across all regulatory reporting schemes and the incentives to use LEI become stronger for every firm and the market as a whole.
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