Global Legal Entity Identifier Initiative

Controlled – Non-Confidential

Dan ThiekeACSDA Senior Summit – December 6, 2013

Data Services

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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

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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)

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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 17442.

•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

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Global Regulatory Community LEI Initiative

FSB delivered initial recommendations to G20 in June 2012.

FSB transitioned its responsibilities to the Regulatory Oversight Committee (ROC) in January 2013. 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.

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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

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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 17442 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

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CICI Utility Functionality

Registration

Self-registration

Assisted registration

Web vs. Bulk file registration

Number Assignment

SWIFT assignment of ISO 17442 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