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© DTCC LEI and CICI update Andrew Douglas ) November 2012
© DTCC Objective of LEI Enable consistent and accurate identification of all legal entities that are parties to financial transactions. Benefits For regulators: Strengthen systemic risk capabilities by allowing accurate, consistent, reliable and timely analysis of position and transaction reports across all legal entities, jurisdictions, and asset classes. For institutions: Increase the ability of financial institutions to accurately report to regulators, interact with other firms and to improve their risk management capabilities. What is an LEI? 2
© DTCC Support for LEI 3 EU Internal Market Commissioner Michel Barnier - Speech of February 10 th 2011 “We must also work together in a common identification of market players. This is an area where the U.S. is already committed, but that requires global standards. G-20 – Cannes Summit Final Declaration - November 4 th 2011 “We support the creation of a global legal entity identifier (LEI) which uniquely identifies parties to financial transactions. We call on the FSB to take the lead in helping coordinate work among the regulatory community to prepare recommendations for the appropriate governance framework, representing the public interest, for such a global LEI by our next Summit.” IOSCO-CPSS – ‘Requirements for OTC derivatives data reporting and aggregation’ - August 24 th 2011 “A system of LEIs would be an essential tool for aggregation of OTC derivatives data, and [IOSCO] recommends the expeditious development and implementation of a standard LEI.”
© DTCC FSB Recommended LEI Infrastructure 4 Local Operating Unit (LOU) Central Operating Unit (COU) Board of Directors Regulatory Oversight Committee Governance Operations International financial market regulators Upholds governance principles Oversees that global LEI system functions for public interest Made up of Plenary & Executive Committee Oversees functioning of COU, operational integrity and implementation, maintenance of standards specified by the ROC Appointed & overseen by ROC, composed of stakeholders from financial & nonfinancial firms Ensures the application of uniform global standards /protocols Manages federation through LOUs Maintains a central logical database of identifiers and corresponding reference data Local provision of all LEI functions which the ROC determines do not need to be centralised. Service providers such as local registries and numbering agencies 4
© DTCC Global LEI (FSB) – timeline 5 How? Implementation Group of regulators very active since mid August 2012 PSPG group of 200 industry experts active across 9 work streams 1.Governance & Legal – 3 sub-groups 2.Operations – 4 sub-groups 3.Ownership and Hierarchy data – 2 sub-groups Key Deliverables Infrastructure in Place 2013 & BeyondQ1 2013Q4 2012Q October 2012 Legal framework for ROC & COU complete Q – Q Implementation group develops standards & operational system for COU Ongoing Maintain standards for connection of LOUs to network Ongoing LOUs internationally connected to COU March 2013 Central Operating Unit (COU) in place, system is self standing November 2012 Regulatory Oversight Committee (ROC) charter endorsed by G20 End of 2012 ROC formed from regulators internationally
© DTCC CFTC – key dates 6 CFTC CICI codes July 24 th CFTC order identifies DTCC-SWIFT as CICI issuer for 2 year term CICI Utility portal goes live August 19 th Ongoing engagement in FSB LEI programme CFTC reporting SWAP definition finalised August 13 th 12 th October 2012** Applies to SD/MSP for Credit and Interest Rates asset classes 11 th January Applies to SD/MSP for Commodities, Equities and FX 12 th April Applies for all non-SD/MSP for all asset classes **CFTC Q&A on Sep 10 th the swap dealer registration regulations go into effect on October 12, and entities that have more than the de minimis level of dealing (swaps entered into after Oct 12) must register by no later than two months after the end of the month in which they surpass the de minimis level. By way of example, if an entity reaches $8 billion in swap dealing the day after October 12, then the entity would have to register within two months after the end of October, or by December 31.
© DTCC CICI Utility 7 New web portal is Open access to Search & view New CICI Registration – self and 3 rd Party Full & Delta file downloads daily (ftp also available) Certify existing CICI’s Challenge existing CICI’s 24,000 CICI’s migrated from test files to live database Operations and customer service teams in place
© DTCC CICI Utility - Sample Record 8
© DTCC CICI Solution IN Legal Entities including Funds Ultimate parent (primary parties only) Registered address Multi language registration Full & delta file download and FTP OUT Individuals, Branches, Divisions, Sub- accounts Immediate parent Operating & settlement addresses Other Relationships e.g. IM to fund Cross-referencing LEI to other identifiers TO FOLLOW Bulk registration (Buy Side) Headquarters Address Expiry date & reason Registry name and number 9
© DTCC Contacts and resources 10 Mark CICI Customer ServiceCICI CICI Web portalCICI Utility https://www.ciciutility.org LEI Further readingGFMA
LEI – Legal Entity Identifier 27 March Why a Legal Entity Identifier ? Driver: –New regulatory framework for swaps (US, Canada, Hong Kong, Australia.
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