Global Legal Entity Identifier Initiative Controlled – Non-Confidential Dan Thieke ACSDA Senior Summit – December 6, 2013 Data Services 1

© DTCC LEI Key Public Policy Objective Strengthen systemic risk capabilities of regulators to analyze positions and transactions of firms they oversee on a globally integrated basis 2

© DTCC New Acronyms (like any good project) GLEIS: Global LEI System ROC: Regulatory Oversight Committee GLEIF: Global LEI Foundation COU: Central Operating Unit LOU: Local Operating Units ISO 17442: The Standard CICI: CFTC Interim Compliant Identifier GEI: General Entity Identifier (Europe) 3

© DTCC LEI Must Be Standardized Globally The LEI is a single unique 20-character alphanumeric code that is assigned to all entities that are counterparties to financial transactions and listed in an open database, available to all as a public good. The FSB and ROC have endorsed and adopted ISO Standard Legal Name – Nestle SA Address – Avenue Nestle 55, Vevey, Vaud 1800, Switzerland Country of formation – Switzerland Business Registry name and number Entity Status – Active Legal Form – Societe Anonyme Dates of first assignment, last update Date and reason for expiry KY37LUS27QQX7BB93L28 4

© DTCC 5 Global Regulatory Community LEI Initiative  FSB delivered initial recommendations to G20 in June  FSB transitioned its responsibilities to the Regulatory Oversight Committee (ROC) in January The ROC adopted the FSB principles.  In March 2013, ROC set out criteria for issuance of the pre-LEI identifiers that could provide an interim solution for the establishment of the Global LEI System consistent with FSB LEI principles.  In October 2013, the ROC announced its first three globally endorsed LOUs, including DTCC’s CICI Utility.

© DTCC 6 Regulatory Initiatives - Europe/North America Commodities Futures Trade Commission (CFTC) Swap Recordkeeping and Reporting Rule (Part 45) All swap counterparties subject to CFTC jurisdiction must have a CICI  Deadline was April 10, 2013 EMIR (December 19, 2012) Reporting on February 12, 2014 Securities and Exchange Commission (SEC) – Investment Advisors On October 31, 2011 the SEC adopted new reporting requirements for certain advisers to hedge funds and other private funds. SEC-registered investment advisers with $150mm in private fund assets under management must file a new form (Form PF) with the SEC Canadian Securities Regulators – Consultation on Rules Relating to Derivatives (December 2012) Proposes that all counterparties to transactions be identified by a legal entity identifier. It is envisioned that this identifier be a Legal Entity Identifier (LEI) from the Global LEI System 

© DTCC 7 CICI Utility Operational Principles Global Can support reporting across all jurisdictions and asset classes Can easily support federation of registration, data maintenance, validation Extensive global industry input to shape solution Public good Cost recovery model Free and unrestricted access Control Built to deliver ISO standard High quality data is a key focus Utility strength infrastructure Expertise Over ten years of data validation expertise through Avox Database already houses over 75,000 ISO-compliant LEIs

© DTCC 8 CICI Utility Functionality  Registration  Self-registration  Assisted registration  Web vs. Bulk file registration  Number Assignment  SWIFT assignment of ISO standard  “5493” prefix beginning end of November  90,000 CICIs are now globally accepted  Validation  All registrations validated against publicly available sources  Result of validation published  Publication  Free full and delta files published daily  Free internet search  Data Quality/Maintenance (Avox processes)  Public challenge process  Annual re-certification  Refresh at least annually