For Immediate Attention:
It is Time to Obtain a Legal Entity Identifier (LEI)
A wide universe of market participants will shortly be required to have an LEI under forthcoming Europeanregulation; this will apply to non-EU entities in many cases. Other regulators, including those in the US andAsia-Pacific, already require market participants to obtain LEIs. Firms large and small need to act now toensure they comply.

What is an LEI?
• The LEI is a unique 20 character
ISO1 identifier for a legal entity thatparticipates in a financial transaction.
Once a legal entity obtains an LEI code,
the code stays with the legal entity for
its existence. Special rules apply for LEIs
regarding natural persons. For more
information, visit: www.gleif.org.

Why do I need to obtainan LEI now?

Will I be affected byforthcoming regulation?

Does this only affect
Europe?

Under upcoming EU regulations, clientsof investment firms, including sub-funds,
intermediaries and wealth clients, will berequired to have an LEI, even if:• No. Regulators around the globe,
including the Commodity Futures TradingCommission4, Securities and Exchange
Commission5, Reserve Bank of India6, andcertain Canadian provincial regulators7
already require or will require entities
to obtain an LEI.

• They are not an EU entity;• They are not operating or domiciled inthe EEA;
• They are not directly subject to EUregulations;• MIFID II/MIFIR and EMIR will also affect nonEU market participants in numerous cases.
• Global standard-setting initiatives havealso called for use of the LEI, including
CPMI-IOSCO8.

 ew European rules will mandate both EUNand non-EU market participants to obtainan LEI in a variety of circumstances in orderto trade or clear:• They are the non-reporting counterparty;• From November 1, 2017: Under theEuropean Market Infrastructure Regulation(EMIR), EU trade repositories will beobligated to reject trade reports that donot contain an LEI2.

• Funds and sub-funds cannot share an LEI;

• From January 3, 2018: The revised
Markets in Financial Instruments Directiveand Regulation (MIFID II/MIFIR)3 require
investment firms to obtain an LEI fromtheir clients prior to providing a service
that would result in a transaction reportingobligation. Market participants will not
be able to trade with in-scope investment
firms if they do not have an LEI.

Example scenarios

Do LEIs need to bemaintained?

Counterparties that will be required tohave an LEI under MIFID II/MIFIR:• Yes. Each legal entity is required to recertify
its LEI annually to ensure the data is accurate.

How do I obtain an LEI?
• Contact any LEI issuer (http://isda.link/gleifissuelei), or the sales or relationshipcontact at your counterparty firms.
• An LEI is issued within 24 to 48 hoursof application. Registration costs about
US$220; renewals cost US$120.

1: http://isda.link/iso17442

2: http://isda.link/emir• They had no previous obligation to get one.
Each legal entity requires an LEI:• Each sub-fund must get its own LEI;
• A subsidiary cannot rely on a parent LEI.

✓ A non-EU entity trades with an EU entity;✓ A non-EU entity trades a derivative with
an EU bond underlying with an EEA
branch of a non-EU entity;• A full list of regulations that mandate theuse of LEIs, and global initiatives thatrecommend their use, is provided by theGlobal LEI Foundation: http://isda.link/gleifregs.

Questions?
ISDA
ISDADataReporting@isda.org✓ An investment manager, delegated entity
or trading advisory (decision-makers),
acting under a discretionary mandate
on behalf of its underlying client (fund/sub-fund), places a share order with an
EU entity. For MIFID II, the decision-makerneeds an LEI. For EMIR, the underlying
fund/sub-fund needs an LEI;

www.isda.org✓ All EU entities.

www.gfma.org

3: http://isda.link/mifidiimifir

4: http://isda.link/cftc

5: http://isda.link/sec

GLEIF
Info@gleif.org
www.gleif.org
GFMA
LEIinfo@gfma.org

6: http://isda.link/rbi

7: eg: http://isda.link/cad© ISDA 2017. The information contained within does not constitute legal advice. ISDA assumes no responsibility for any use to which the information contained herein may be put.

8: http://isda.link/uti