Legal Entity Identifiers

News & Analysis as of

New FERC NOPR Will Have Impacts on the Financial Trading Community

On Thursday, July 21, 2016, FERC issued a new Notice of Proposed Rulemaking on Data Collection and Surveillance, which is to replace the prior Connected Entities and MBR Ownership NOPRs. The new NOPR will apply to: (1)...more

FinCEN Issues Final Rule on Customer Due Diligence Requirements for Legal Entity Customers

On May 11, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) published its Final Rule (Rule) requiring covered financial institutions, including, banks, brokerdealers, mutual funds, and money...more

CFPB to participate in Financial Data Summit

The CFPB is among the federal agencies participating in a Financial Data Summit hosted by the Data Coalition to be held on March 29, 2016 in Washington, D.C. Linda Powell, the CFPB’s Chief Data Officer, will be on a panel...more

Blasphemous Corporate Names

Yesterday’s post considered the question of whether the California Secretary of State could refuse to accept offensive corporate names. Blasphemous corporate names constitute a subset of offensive names because they are...more

NFA Issues Notice on the Inclusion of Legal Entity Identifiers in the Swap Dealer/Major Swap

The National Futures Association (NFA) has issued Notice I-15-28, which discusses the legal entity identifiers (LEIs) that are now being used in the NFA’s swap dealer/major swap participant registry (SD/MSP Registry). The...more

LEIROC reports on GLEIS

LEIROC has published a report on the Global Legal Entity Identifier System (GLEIS) and regulatory uses of the LEI in a letter to FSB. LEIROC informs FSB that the GLEIS is now in place. It also describes the results of a...more

LEIROC consults on data in the GLEIS

LEIROC has launched a consultation on incorporating data on branches into the Global Legal Entity Identifier System (GLEIS). LEIROC proposes a policy standard for the GLEIS that would allow Legal Entity Identifiers (LEIs) to...more

ESMA updates EMIR implementation Q&A

ESMA has updated its Q&A on the implementation of European Market Infrastructure Regulation (EMIR). The update gives guidance on a procedure for counterparties and...more

LEIROC issues statement on individuals in a business capacity

In response to enquiries on the eligibility of individuals acting in a business capacity to register for an LEI, LEIROC has issued a statement. LEIROC clarifies that individuals acting in a business capacity are eligible to...more

FERC Seeks to Expand Electricity Market Surveillance with New Data Reporting Requirements

On September 17, 2015, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) to expand the obligations of Regional Transmission Organizations and Independent System Operators...more

"Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson"

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border...more

LEIROC consults on collecting parent data in the GLEIS

LEIROC has published a consultation on collecting data on direct and ultimate parents of legal entities within the Global Legal Entity Identifier System (GLEIS). It seeks views on: - uses of relationship...more

CFTC Extends Designation of DTCC-SWIFT as Provider of Legal Entity Identifiers

On July 20, the Commodity Futures Trading Commission issued an order extending the designation of the Depository Trust and Clearing Corporation and Society for Worldwide Interbank Financial Telecommunications joint venture...more

U.S. SEC Approves Proposal to Modernize Investment Company Reporting Regime

The U.S. Securities and Exchange Commission (SEC or Commission) unanimously approved a proposal (Proposal) to modernize the reporting of information provided by registered investment companies (funds). Guided by the recent...more

Financial Regulatory Developments Focus - March 2015 #3

In this issue: - US Federal Reserve Board Proposal Requiring Banking Organizations to Include Legal Entity Identifiers on Reporting Documents - Comptroller of the Currency Thomas Curry Testimony -...more

Federal Reserve Board Proposes to Include Legal Entity Identifiers in Certain Banking Organization Reporting

One difficulty encountered by national banking authorities during the course of the 2008 global financial crisis was identifying the ultimate parent for the trades made by various subsidiaries of dealers. To assist in...more

FCA Requirement for Legal Entity Identifiers

On November 7, the UK Financial Conduct Authority (FCA) has confirmed that it will require all financial institutions conducting business in or from the United Kingdom to have a Legal Entity Identification (LEI). This...more

Application of the European Market Infrastructure Regulation to Alternative Investment Fund Managers

European investment managers of non-UCITs funds will have to be authorised as an alternative investment fund manager (known as an “AIFM” under AIFMD) under the Alternative Investment Fund Managers Directive (“AIFMD”) from 22...more

Information Letter: Update on legislative developments in Russia. Governmental De-offshoring initiatives. Proposed new CFC and...

When it was first revealed by President Vladimir Putin a few years ago that the offshore-backed modus operandi for the Russian economy could no longer be tolerated, very few could have predicted that the Government would be...more

Delegation’s What You Need: EMIR Reporting for SPVs

Introduction - European Market Infrastructure Regulation (EMIR) has been in force since 16 August 2012. It is concerned with improving the transparency of, and reducing the risks associated with, the derivatives...more

Two Months to Comply With European Reporting Rules for Derivatives – What Buy-Side Entities Need To Know

Many of the provisions of the Regulation on Derivative Transactions, Central Counterparties and Trade Repositories, known as the European Market Infrastructure Regulation 648/2012 (“EMIR”), are now in effect throughout the...more

CFTC Announces Mutual Acceptance of Approved Legal Entity Identifiers

The CFTC announced that registered entities and swap counterparties subject to the CFTC’s jurisdiction may now comply with the CFTC’s swap data recordkeeping and reporting requirements with respect to Legal Entity Identifiers...more

CFTC Announces Mutual Acceptance of Approved Legal Entity Identifiers

On October 30, the Commodity Futures Trading Commission’s chief information officer announced that registered entities and swap counterparties subject to CFTC swap data recordkeeping and reporting requirements concerning...more

CFTC Amended Order for Mutual Acceptance of LEIs

On June 10, the CFTC issued an amended order that revises an order issued on July 23, 2012, expanding the list of approved providers of Legal Entity Identifiers (LEIs) that can be used by registered entities and swap...more

Orrick's Financial Industry Week in Review - June 24, 2013

In This Issue: OCC Issues Final Rule on Lending Limits; CFTC Temporary No-Action Relief for Transition to SEF Rule; FHFA Report to Congress; CFTC Temporary No-Action Relief for Small Bank Board Approval Requirements: CFTC...more

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