Global Legal Entity Identifier Update

for ACSDA General AssemblyApril 4, 2014

Controlled – Non-Confidential

William HodashManaging Director, DTCC

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

• COU: Central Operating Unit

• Pre-LOUs: Pre-Local Operating Units

• Pre-LEIs: pre legal entity identifiers

• ISO 17442: The Standard

• GMEI Utility: Global Markets Entity Identifier Utility (DTCC/SWIFT Collaboration)

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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 – Eastspring Investments (Singapore) Limited•Address – 10 Marina Boulevard, #32-01, Singapore, 018983•Country of formation – Singapore•Business Registry name and number - Accounting and Corporate Regulatory Authority (ACRA), 199407631H

•Entity Status – Active•Legal Form – Limited•Dates of first assignment, last update – 2014-01-24, 2014-02-07•Date and reason for expiry – N/A

549300T0KLGA41EVVR68

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Industry LEI Initiative Evolution

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• Driven by need for systemic risk analysis– Office of Financial Research (OFR) formed

• Given a specific request from the U.S. Office of Financial Research (OFR) for an industry driven consensus on legal entity identification:

– The financial services industry, working through GFMA, formed the Global Trade Association group to formulate a proposal

– Objective to develop a global, consensus-based solution for the accurate and unambiguous identification of legal entities engaged in financial transactions

• The Financial Stability Board (FSB) involvement to drive global adoption• The International Organization for Standardization approved ISO 17442 in May 2012• CFTC Requirements for CICI issued Spring 2012 and require all market participants to have CICIs

by April 10, 2013•Utility Formed in response to industry requirements and use mandated by CFTC– Data collection, maintenance, LEI assignment, QA

- The Depository Trust & Clearing Corporation (DTCC) - Society for Worldwide Interbank Financial Telecommunications (SWIFT) - Federated Registration – ANNA- GMEIutility.org

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Key Industry Requirement: Data Quality

Challenges of Maintaining Data Quality

• Maintaining singularity (i.e., no duplication)

• Ensuring initial and on-going accuracy– Self-registration and on-going maintenance is neither mandated nor does it

ensure accuracy– Official jurisdictional Entity Registries tend to be non-public, incomplete, and

periodically updated– Applying corporate actions in a consistent manner across jurisdictions is difficult– Thus, validation is essential

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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 July 2013, The ROC published a framework for global endorsement of pre-Local Operating Units

In October 2013, the ROC announced its first three globally endorsed pre-LOUs, including DTCC’s CICI Utility. There are now ten endorsed pre-LOUs.

In October 2013, ESMA stated that reporting to TRs (beginning in Feb 2014) must include pre-LEIs - - October 2013

ROC is currently working on a common file format for all pre-LOUs

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Key Current Issues in the GLEIS

Portabilityo Principles and Practice

Common File Layouto Standardization will facilitate consumption and consolidated file

Global Endorsemento Critical prior to issuance of pre-LEIs

Asset Class Expansiono Moving beyond OTC Derivatives

Data Quality/Maintenanceo Requiring entities to maintain

Establishing the GLEIS Foundation/Central Operating Unito Necessary step for pre-LEIs to become LEIs

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GMEI Utility

• The endorsement of the CICI Utility by the Regulatory Oversight Committee (ROC) allows DTCC/SWIFT to offer the legal entity identifier service globally

• We have now adopted the name Global Markets Entity Identifier (GMEI) utility to reflect the global acceptance of the utility’s pre-LEIs across multiple jurisdictions, and to reflect the broad asset class coverage.

• New Name, Same Portal:

• The identifiers of all endorsed pre-LOUs are referred to generically as pre-LEIs and when the GLEIS is fully operational they will be called LEIs. They are accepted by all 55+ regulators who endorsed the ROC charter, including the CFTC and ESMA.

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GMEI 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 110,000 ISO-compliant, globally accepted pre-

LEIs

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GMEI Utility Functionality

Registration Self-registration Assisted registration Web and Bulk file registration

Number Assignment SWIFT assignment of ISO 17442 standard “5493” prefix since November, 2012

Validation All registrations validated against publicly available sources Result of validation published

Publication Free full and delta files published daily Free internet search

Ongoing Data Quality/Maintenance Public challenge process Annual re-certification

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Global Registrations & Market Share by Pre-LOU

125480; 54.8%

44097; 19.3%

18670; 8.2%

14970; 6.5%

7872; 3.4%

7182; 3.1%

3815; 1.7% 3644; 1.6% 1684; 0.7% 1602; 0.7% 27; 0.0% 28; 0.0%

GMEI utilityGEI - GermanyLondon Stock ExchangeINSEE - FranceKvK - NetherlandsUnioncamere - ItalyCSD Prauge - Czech RepublicKDPW - PolandIrish Stock ExchangePRH - FinlandNSD - RussiaTakasbank - Turkey

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Top 10 Countries by Pre-LEI Registrations

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United St

ates

German

yFra

nce

Luxembourg

United Kingd

om

Netherl

ands

Italy

Cayman

Islan

ds

Swed

enIre

land

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100% 99.1%

6.9% 8.2%

63.9%

40.3%

16.5%13.3%

96.1%

81.6%

58.8%

GMEI utility Market Share per Top 10 Country

United St

ates

German

yFra

nce

Luxembourg

United Kingd

om

Netherl

ands

Italy

Cayman

Islan

ds

Swed

enIre

land

0

10,000

20,000

30,000

40,000

50,000

60,000

70,00064,505

29,687

17,44214,47412,61210,665 9,349 7,442 5,991 5,674

Top 10 Countries by Pre-LEI Reg-istrations

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Potential Partnership Models

DTCC and SWIFT are open to partnering with CSDs and NNAs. Potential to share:o Expertiseo Technologyo Operating Platformo Revenue

Two types of models:o Facilitator of pre-LEIs issued by GMEI Pre-LOU/Register customer with their

express permissiono Form own pre-LOU sponsored by local regulator/outsource some key

operations to GMEI utility Current Examples:

o CUSIP Global Serviceso NordLEIo More coming soon