It is extremely important that regulators coordinate disparate Legal Entity Identifier (LEI) efforts taking place across regulatory agencies and across jurisdictions – creating a single LEI standard across regulators will allow for more effective regulatory oversight and be more efficient for firms.  We appreciate the Office of Financial Research’s (OFR) outreach to foreign regulators, as a globally coordinated approach will be necessary for effective implementation.  SIFMA and the financial industry are committed to finding the right solution for an LEI standard, but we are working on a very tight timeframe and hope that pre-existing deadlines do not prevent us from developing the right structure to meet policy goals.

SIFMA believes it is critical that regulators consider the following preliminary concepts, as we begin the rulemaking process:    

• Global coordination is critical to developing a single LEI standard which can be used internationally, making this a powerful tool for firms and regulators to manage and monitor systemic risk;
• Regulators should clearly define who is responsible for obtaining an LEI, and preliminarily we see benefits to a self-registration model in which legal entities would register a limited amount of information about themselves and then would certify that information periodically, or upon changes;
• SIFMA agrees in concept with the LEI characteristics contained in the cross-regulatory whitepaper entitled “Creating a Linchpin for Financial Data: The Need for a Legal Entity Identifier,” especially that the LEI be neutral without any embedded intelligence;  
• The data elements for the LEI process should be considered carefully and should likely include some corporate hierarchy information;
• It is important to have a carefully thought out strategy to phase in the use of LEIs;
• The entity responsible for the LEI process (the LEI “issuer”) should operate on a non-profit or an at-cost recovery model, with a stable funding source and an open and transparent process;
• Data should be freely available, without restrictions on reuse or redistribution, and in line with any jurisdiction’s regulations on privacy.

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