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LEI for clients as Legal Persons
The temporary process outlined in ESMA’s statement for LEIs of legal persons will last for six months from 3 January 2018.
As ESMA’s statement notes, this approach requires the FCA to temporarily amend a validation rule in our transaction reporting system, the Market Data Processor (MDP). FCA will do this as soon as possible, but that change will not be made by 3 January.
FCA will communicate further with executing firms and Approved Reporting Mechanisms (ARMs) on this issue, including the date when we intend to make the change to the validation rule related to the LEI issuance date. Until then, executing firms should not seek to submit reports that would not normally pass that validation. FCA will have the facility to accept these reports when the validation rule change has been made.
FCA continue to expect firms to make every effort to secure a clients’ LEI before trading on their behalf. The analysis shows that trading with missing LEI is likely to represent a very small fraction of total trading volumes.
LEI for Issuers
The FCA notes the ESMA statement on LEI for Issuers, which allows venues, for a period of six months, to use their own LEI in place of missing issuer LEIs in respect of non-EEA issuers.
Venues should continue their efforts to populate missing LEI data for issuers. Supervisors will be in contact with venues to discuss their progress in reducing the number of missing LEIs.