What is the LEI?
The Legal Entity Identifier (LEI) is a reference code — like a bar code — used across markets and jurisdictions to uniquely identify a legally distinct entity that engages in a financial transaction. The LEI is designed to be a linchpin for financial data — the first global and unique entity identifier enabling risk managers and regulators to identify parties to financial transactions instantly and precisely. A large international bank, for example, may have an LEI identifying the parent entity plus an LEI for each of its legal entities that buy or sell stocks, bonds, swaps, or engage in other financial market transactions.
Why do we need the LEI?
When Lehman Brothers collapsed in September 2008, regulators and private-sector firms were unable to assess quickly and fully the extent of market participants’ exposure to Lehman and how the vast network of market participants was connected. The financial crisis underscored the need for a global system to identify financial connections, so regulators and private sector firms could better understand the true nature of risk exposures across the financial system.
The establishment of the global LEI system is a significant achievement that responds to these vulnerabilities and provides meaningful, long-term benefits for the public and private sectors.
The financial industry’s adoption of the global LEI means data reported externally to regulators and used internally for risk management will be more consistent and usable. This will help regulators to better analyze and monitor the stability of and threats to the financial system. This will also enable companies to improve internal management of operational risks and cut costs tied to collecting, cleaning, and aggregating data, and in reporting data to regulators.
If a global LEI is so useful, why wasn’t it established sooner?
Private industry made several attempts over the past 20 years to establish a global entity identification system but failed to achieve the coordination needed to launch a single global solution. After the financial crisis in 2007-09, leaders from the world’s largest economies, operating through the G-20 and Financial Stability Board (FSB) agreed to develop a coordinated solution to help overcome these impediments. This effort resulted in a public-interest initiative that is now the global LEI system.
The OFR, acting under its statutory mandate to prepare and publish a financial company reference database and its mandates pertaining to data standards and standardization, was instrumental in this effort. In November 2010, the OFR issued a policy statement calling for a global LEI system. Representatives from the financial industry welcomed the call, responded with a proposed solution, and worked together through the FSB to develop a global LEI system. Throughout the FSB process, the OFR played a key role by leading work streams and working with other regulators and industry to provide recommendations to the G-20 to guide the governance, development, and implementation of a global LEI system.
In January 2013, finance ministers and senior financial supervisors of the world’s largest economies, working through the FSB, agreed to assign responsibility for overseeing the global LEI project to the Regulatory Oversight Committee — a group of more than 50 regulators and representatives from around the globe. Among their earliest decisions, committee members appointed an OFR official as their first chairman.
The OFR has worked with other U.S. regulators to embed the concept of the LEI into rulemaking for financial reporting requirements and will continue to do so. In the United States and Europe, LEI use was first used in swaps regulation.
How does the LEI work?
Each LEI is a 20-digit alphanumeric code and associated set of reference data items to uniquely identify a legally distinct entity that engages in financial market activities. This global standard meets the 2020 specifications of the International Organization for Standardization (ISO), as documented in ISO 17442-1:2020, Legal Entity Identifier (LEI).
Successful operation of the global LEI system requires support from the global regulatory community, private sector firms and industry associations. Regulators oversee the system through the Regulatory Oversight Committee, which publishes updates about its work at www.leiroc.org.
The committee consulted with private industry to develop a central operating unit, the Global LEI Foundation, which began taking operational responsibility in late 2014. The foundation is led by a 16-member board of directors, all from the private sector. The role of this central operating unit is to ensure that all parties that implement the LEI adhere to governing principles and standards, including reliability, quality, and uniqueness — essential for achieving the shared goal for “one golden standard” for the LEI.
Each LEI code is assigned by an approved local operating unit, which benefits from local knowledge of infrastructure, corporate organizational frameworks and business practices.
To obtain an LEI from any local operating unit, a company pays an initial registration fee, followed by an annual maintenance fee to help cover these units’ operating costs. Each unit is required to share a portion of those fees with the nonprofit Global LEI Foundation.
What are the next steps?
Some of the largest multinational banks have thousands of legal entities, many with similar names, operating around the globe. As the global LEI system expands, it is expected to help regulators and market participants understand and document these complex corporate structures and hierarchies.
Data about the relationships can show networks of control, ownership, liability, and risks, giving financial regulators deeper insights into how market participants are connected to each other. The OFR is helping a working group established by the Regulatory Oversight Committee examine ways to add corporate hierarchy information to the global LEI database.
When will the LEI become widely used by market participants and regulators?
The OFR is committed to promoting widespread adoption of the global LEI and is working with U.S. regulators to expand the use of the LEI in regulatory reporting requirements. The OFR has argued that several key datasets — including call reports filed by banks, securities financial reports and offering materials — should require use of the LEI.
Already, financial regulators from the United States, the European Union, the United Kingdom, Canada, Australia, Singapore and other markets around the world have adopted reporting rules that require companies to use the LEI.
In the United States, the Commodity Futures Trading Commission, the Securities and Exchange Commission, the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the OFR, the Consumer Finance Protection Bureau, the National Association of Insurance Commissioners, and the Municipal Securities Rulemaking Board have all adopted rules requiring or are encouraging companies to use the LEI in their regulatory filings or reporting.
How does the LEI system benefit industry?
As the global LEI becomes more widely used, it should cut costs and improve risk management for individual firms and across the financial system. These savings will come from reducing transaction failures, lowering data reconciliation, cleaning, and aggregation costs; and trimming regulatory reporting costs.
A global LEI system will provide long-term benefits to companies by clearly identifying their counterparties — the firms they transact with — and the customers they serve, making internal risk management easier. According to industry estimates, universal adoption of the global LEI system could save the financial sector from $300 million to $10 billion.