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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 reducing that difficultly the Financial Stability Board in January 2013 established the Regulatory Oversight Committee ("ROC"), a group of over 60 public authorities from more than 40 countries, to coordinate and oversee a worldwide framework of legal entity identification, the Global LEI System. The Legal Entity Identifier ("LEI") is a 20-digit, alpha-numeric code, that uniquely identifies legally distinct entities that engage in financial transactions. The term "legal entity," as defined in the standards established by the International Standards Organization ("ISO") for financial services LEIs, includes unique parties that are legally or financially responsible for the performance of financial transactions or have the legal right in their jurisdiction to enter independently into legal contracts, regardless of whether they are incorporated or constituted in some other way. This includes all financial intermediaries, banks and finance companies, all entities that issue debt, equity or other securities for other capital structures. The LEI supports national financial authorities and market participants in identifying and managing financial risks. In particular, ROC intends for LEIs to be used for trade and regulatory reporting and other supervisory purposes in the various jurisdictions represented in the ROC. The LEI code is associated with reference data for each entity, currently including core identification information, such as the official name of the legal entity, the address of its headquarters and address of legal formation. More than 300,000 LEIs were issued to entities in over 180 countries as of January 2015.

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