New EU rules (MiFID II/MIFIR) took effect on 3 January 2018. According to MiFIR, investment firms should obtain LEIs from their clients before providing services which would trigger related reporting obligations. Help your clients to access the network of LEI issuers and gain data management efficiencies.Become a Registration Agent
The European Union (EU) revised Markets in Financial Instruments Directive (MiFID II) and Regulation (MiFIR), covering trading venues, investment firms and intermediaries, took effect on 3 January 2018. The MiFID II/MiFIR implementing legislative acts require a significant number of actors to obtain a Legal Entity Identifier (LEI) that are under no such obligation to date. With regard to transaction reporting under MiFIR, the European Securities and Markets Authority (ESMA) has clarified that investment firms should obtain LEIs from their clients before providing services which would trigger reporting obligations in respect of transactions carried out on behalf of those clients.
The Global Legal Entity Identifier Foundation (GLEIF) calls on market participants that have to comply with MiFID II/MiFIR to obtain an LEI as soon as possible. Firms should also proactively contact their impacted client base and encourage registration for and renewal of an LEI. Additionally, firms may consider deepening the use of the LEI within their client onboarding infrastructures so as to benefit from the EU-wide use of this common identifier.
To further streamline the issuance of LEIs, GLEIF has introduced the concept of the ‘Registration Agent’. A Registration Agent helps legal entities to access the network of LEI issuing organizations responsible for performing LEI issuance and related services. LEI issuers are also referenced as Local Operating Units or LOUs.
The Registration Agent’s role in the Global LEI System is directly connected to the LEI issuing organization. The Registration Agent may choose to partner with one or more LEI issuing organizations to ensure its clients’ needs for LEI services are met.
Possible tasks performed by a Registration Agent include:
- Publish information on its website to help a legal entity apply for an LEI with an LEI issuing organization.
- Manage communications with the legal entity.
- Process or receive secure payment for the issuance or renewal of an LEI.
- Provide data collection or aggregation services from the relevant authoritative sources. (Reference data provided by the legal entity wishing to obtain an LEI is validated with a local authoritative source – a national Business Register, for example – prior to issuing an LEI compliant with the LEI standard.)
- Validate the legal entity reference data provided by a legal entity that wishes to obtain an LEI.
Possible tasks performed by the LEI issuing organization include:
- Issue the LEI in compliance with ISO 17442:2012 standard along with the pertaining legal entity reference data (LE-RD).
- Upload to GLEIF the new LEI and all LE-RD.
- Review and respond to LEI or LE-RD challenges transmitted by GLEIF. (The centralized challenge facility made available by GLEIF extends the ability to trigger updates of LEI data to all interested parties.)
Registration Agents will neither be responsible for issuing LEIs nor will they have editorial access to LEI data.
The full duties of an LEI issuing organization are specified in the Service Level Agreement, i.e. Appendix 6 to the Master Agreement. The Master Agreement is the contractual framework governing the relationship between GLEIF and LEI issuing organizations. It will always be the LEI issuing organization that remains fully responsible and liable to GLEIF for the execution of its duties.
For more information about Registration Agents, contact RegistrationAgent@gleif.org.