Questions from GS1 to the Global SOl Steering Committee - May 2011 

Thank you for inviting GS1 to submit our response to the Global SOl Steering Committee (the 

Committee) to explain how GS1, its 108 member organizations around the world, and the GS1 System 

not only meets, but exceeds the requirements for a global LEI solution as outlined in the document 

issued by the coaiiiion of giobai financiai-services trade associations on iviay 3, 2011 (Global Legal 

Entity Identifier Solicitation of Interest). 

We agrf;e wholeheartedly that the accumte and unambiguous identification of legal entities participating 

in financial markets is foundational and critically important toward the improved measurement and 

monitoring of systemic risk by financial institutions, regulators and supervisors. \lVe are eager to 

demonstrate why the GS1 System is an excellent fit to become the industry's solution in our final 

response due to the Committee on June 3, 2011. 

In the meantime, below you will find our initial round of questions for the Committee. We !ook forward to 

your responses. !f you require additional c!arification, piease do not hesitate to cont.act Bob Carpenter at 

GS 1 at teiephone 609.620.4565 or emaii bcarpenter@gs1 us.org. Again, thank you for your efforts to 

continue coordinating industry activities. 

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1. In the interests of an open and transparent process on behalf of the industry, GS1 

would like to confirm \•;hether and when the Committee wil! publish the following: 

• The identities of the organizations that express their intent to respond to the 

SOl; 

.. ;·11-.1! questions submitted by respondents to the committee in each of the two 

submission periods; 

• The committee's corresponding answers to all questions submitted by 

respondents; 

• Final submissions received; and 

• The names and affiliations of the individuals on the Committee who will be 

responsible for evaluating responses to the SO! and preparing 

recommendations and/or or endorsements to the OFR and regulators around 

the globe. 

!f the above aspects vvithin the submission piocess \Vi!! not be published, can the Committee explain ... ,!.-.,,,') 

'i!iiij: 

2. In the SOl, you explain that each response will be assessed for completeness and 

responsiveness. Beyond those broad categories; can you p!ease describe in more 

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detail the process for evaluating responses to the SOl and the criteria that will be 

applied? 

3. If the Committee ultimately recommends or endorses one of the proposed 

solutions, what will the process be to obtain consensus among the Committee 

decision-makers for this choice? !f there is not unanimity, ho\•; will this be 

reported? What \Nil! be reported regarding the reasons for the final decision of the 

Cornn;ittee? 

4. The SOl states the Committee's intent of "recommending and/or endorsing the 

solution provider(s) to the OFR and regulators around the globe." Has the OFR, 

SEC, CFTC, or any other regulator in the U.S. or around the globe given the 

Committee a specific role in the regulator decision-making process? If so, please 

exp!ain. 

5. If discrepancies are found between the requirements of the CFTC, OFR and SEC 

and the SO! J ho\n: ¥vii! such discrepancies be addressed? 

6. Will corporations, as issuers and participants in financial markets, and global 

auditing firms, who are interested in precise legal entity structures for their 

materiality attestation function, p!ay a role in the evaluation process? 

7. In our reading of the Requirements for a global Legal Entity Identifier {LEI) solution 

published on the SIFMA website (Requirements for a Global Legal Entity Identifier 

(LEI) Solution - May £u1 ·1), it appeais that iequiiements foi iefeience data 

(minimum data attributes) associated with LEis for regulatory purposes are defined, 

but not the requirements for the structure and allocation of the LEI identifiers 

themselves. !s this a correct interpretation? Does the Committee or coalition of 

trade associations intend to define the requirements of the LEI identifiers 

themselves? If yes, vvhen? If not, vvhy not? 

8. The Committee has not commented whether the LEI needs to have an extension of 

reference data beyond the minimum data attributes, so that it can be further used 

for financial institution business applications. VVhat is the Committee's point of 

view on this? 

9. Beyond the LEI as requested by the OFR are t...vo other definitions of unique, 

unambiguous and universal identifiers required by the US government. These are 

the Unique Counterparty Identifier (UCI) defined by the CFTC, and the Unique 

Identifier Code (U!C) defined by the SEC. The OFR, CFTC and SEC have stated 

their interest in satisfying a!! three required identifiers within a single construct. How 

does this SO! relate to the UC! and UIC? 
10. The SOl uses the term "LEI system," a term that is not defined in the SOl or 

mentioned in the SIFMA requirements document. Section 2 of the SOl could be 

read to imply that an LEI system is a single information system built by a single 

solution provider or solution provider group. Precedents exist in other industries for 

identification systems and reference data to be maintained through a network of 

federated systems operating in accordance with worldwide industry standards. 

Has the committee assumed that an "LEI system" should be a single centralized 

system, excluding the possibility of a federated or distributed model? If so, what is 

the justification for that assumption, given that neither the SIFMA requirements 

document nor the statements issued by the OFR and other regulators define the 

"LEI system" so narro'<vly? 

11. What are the criteria by which the Committee will assess whether a submission 

meets the requirements for "certification"? 

12. What are the criteria by which the Committee wi!! assess whether a submission 

meets the requirements for "self-registration"? 

13. The Committee has not commented about LE! operational implementation. Wi!l it, 

and when? If not, why not? 

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Solicitation of 

Interest Q&A 

Responses to Questions Round 1 
1. As part of the SO! process, wi!! the committee publish information related to the following? 

1) Identity of providers expressing interest 

3} Solution provider submissions 

A: We will make available the following information as part of the SOl process. However, note that not all 

information will be made available immediately. 

1.) Identity of provider expressing interest (disclosed after completion of the entire selection process) 

2) ,LI, consolidated list of questions and their corresponding answers (first set published 5124; second set 

pulJiished 5131) 

3) Solution provider submissions will not be disclosed. However, a list of organizations and trade 

associations involved during the course of provider identification will be disclosed upon the completion 

of the process, so as to preserve the integrity of the process. 

2. Wil! the successful solution provider be able to offer the LEI service as part one of their 

offerings, either en its O\Vn or combined ;ith existing services? 

A: Successful solution provider(s) will be able to offer the LEI service as part of their offerings. However, 

this service must be offered to the public without fees for basic storage, access, cross-referencing or 

redistribution (Requirements Document, Section 9, Page 32). Value-added services based on the 

publicly available database can be freely developed and commercialized, assuming that these services 

are unbundled (i.e., separate from) and voluntary (i.e., not required to access and use LEI information). 

3. Please describe in more detail the SOl evaluation process and the criteria that will be applied to 

A: The criteria for assessing completeness and responsiveness include the "requirements" set forth in the 

LEI Requirements document and the "prerequisites " set forth in the LEI Solicitation of Interest (SOl, 

Section II, Prerequisites, Page 4). These criteria are based on the principles established by the 

regulators in their policy statements. as well as by the requirements developed !Jy the industry 

representatives and trade associations described in the requirements document. 

4. Hc\v \Viii the Committee assess a submission on its LE! certification process? 

A: The criteria for assessing the annual certification process have been set forth in the LEI Requirements 

Document (Requirements Document, Section 7.2, Page 25). We are open to recommendations from 

the solution provider as to the optimal process for performing this certification in accordance with the 

Fl.equirements Document and expect that this process will be detailed in the solution provider's 

submission. 

5. What are the criteria by \•Jhich the Committee wil! assess whether a submigsion meets the 

·requirements for "self-registration"? 

A: The assessment criteria for the self-registration process include the requirements set forth in the LEI 

Requirements Document (Requirements Document. Section 7.1, Page 24) and the "prerequisites" set 

forth in the LEI Solicitation of Interest (SOl, Section 1, Page 4). 

6. Will corporations, as issuers and participants in financial markets, and g!oba! auditing firms, 

who are interested in the precise !ega! entity structures for their materiality attestation function, 

p!ay a role in the evaluation process? 

A: The process participation has been wide-ranging witiJ global industf1J participants. To date, 43 

participating firms and 16 trade associations have been involved in developing the requirements and 

refining the process. All participants have strived to make the process as transparent and inclusive as 

possible by including members from all regions and industries. All stakeholders agree that the 

atmosphere of inclusivity and openness will be carried forward as we move towards identifying one or 

more solution provider(s). 

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7. !f the committee ultimately recommends or endorses one of the proposed solutions, what wil! 

the process be to obtain consensus among the Committee decision-makers for this choice? !f 

there ls not unanimity, how ..,•;Hi this be reported? What •.,.;iii be reported regarding the reasons 

fer the final decision of the committee? 

A: T!?e group is not requiring a unanimous vote on the recommendation, but rather broad consensus from 

the group that established the initial requirements document. The group that developed the initial 

requirements document includes "representation from trade associations and financial services firms 

from a broad range of countries, representing many different types of financial industry participants" 

(LEI Solution Cover Letter, Page 1). 

5. !n our reading of the Requirements for a global Lega! Entity Identifier (LEI) solution pub!ished 

on the SIFMA website (Requirements for a Global Lega! Entity Identifier (LEI) Solution - May 

2011), it appears that requirements for reference data (minimum data attributes) associated with 

LEis for regulatory purposes are defined, but not the requirements for the structure and 

allocation of the LEI identifiers themselves. Is this a correct interpretation? Does the Committee 

or coalition of trade associations intend to define the requirements of the LEI identifiers 

themselves? If yes, \•!hen? !f not, why not? 

A: It is our expectation that the solution provider will draw on best practices and experience to define 

requirements and standards related to structure and allocation as part of their submission. For greater 

details on attribute definitions, metadata definitions and registration/distribution please refer the 

requirements document. (Requirements Document. Section 6.1. 6.2 & 6.3. Pages 21-22 and Section 

7.1 & 7.3, Pages 24-25). 

9. The Committee has not commented whether the LE! needs to have an extension of reference 

data beyond the minimum data attributes, so that it can be further used for financial institution 

business applications. What is the Committee's point of vie\•; on this? 

A: At present, we are only requiring the elements included in t/Je requirements document (Requirements 

Document, Section 6.2. Page 20). Additional items may be added in the future as demand presents 

itself,· however, all additional elements are subject to the oversight and the approval of the LEI 

Governance Body. 

10. B~yond !he LEI as requested by the OFR are t~a1o other definitions of unique, unambiguous and 

universal identifiers required by the US government. These are the Unique Counterparty 

Identifier (UCI) defined by the CFTC, and the Unique Identifier Code (UIC) defined by the SEC . 

The OFR, CFTC and SEC have stated their interest in satisfying ali three required identifiers 

within a single construct. How does this SO! relate to the UCI and UIC? 

A: lt'v'e highly recommend that the LEI be used to satisfy the identifier requirements from the CFTC and 

the SEC. We promote a single, industry-wide LEI standard supported by all regulators globally. For 

further discussion. please see the "Critical Dependencies" section of the Requirements Document 

(Requirements Document, Section 4, Page 14). 

11: Please comment on the usage of the term .. LEI System II in the SOi document and V!!hether the 

committee envisions the eventual soiution to be a centraiized OR a federated/distributed modeL 

A: We are committed to developing a solution t!Jat meets or exceeds the requirements detailed in the 

Requirements Document. To that end. we are open to both centralized and distributed/federated 

models as long as the model operates off a standardized LEI format wit!? t!?e required data attributes as 

outlined in the Requirements Document (Requirements Document, Section 6.2, Page 20) 

12~ uFraud: Legal entity kno~~~ing!y misrepresents its LE information~ u and 11Errors: Legal entity 

knowingly misrepresents its LE information." (Section 7.5, Page 26). Is there a requirement for 

the LEI Solution provider to revle•t,; and certify each submission prior to the entity being 

incorporated v·.Jithin the LEI so!t~Iicn {or at least for the entity to be appropriately flagg~d as 

3 
"Unverified"), or is the requirement merely that a series of systematic data checks and random 

SOH.itHJi1 t 

A: There are four main points in the end-to-end LEI Solution process that will allow for the LEI Solution 

provider to review and certify each submission to ensure data quality-- initial registration. corporate 

actions (when legal entity information changes), annual certification process and continue! date quality 

assurance. Although "the legal entity itself has the ultimate responsibility for maintaining the accuracy 

of the date associated with its LEI" (Requirements Document. Section 7.2, Page 25) it is our 

expectation that the solution provider will propose and adopt necessary processes and support to veri!'! 

information at all four of the above stages. Additional information on each of those stages are available 

in the Requirements Document in Section 7.1 -7.5, Pages 24-26 respectively. 

13. With regards to requirement for consumers to be able to raise a "Request for Review", this 

tJrovision may give rise to potential malicious or erroneous "Request for Revie1l .. l" submissions. 

(Section 7~41 Page 26)~ In order Io reduce the occurr~nce cf such Y\!Ouid there be a requirement 

to provide an anonymised history of aU previous chaiienges and responses/supporting 

documentation is of vgfu~? 

A: We expect the solution providers to include in their response. decisions and the processes to react to 

these types of situations. 

14. Please clarify "During an extended ..... and an alternative mechanism for assigning LEis to 

entities that are not required to have an LEI and choose not to self-register. If an entity is not 

required to have an LEI; then why \\!ould the Sc!uticn provider assign cne? (Section 7~1, Page 

24) 

A: \Nhi!e a legal entity may not have a regulatory requirement to register for an LEI, the counterparties that 

it interacts with that do have regulatory reporting requirements may need to report transactions and/or 

to regulators with information about all parties to the trades. Thus, there will be a need for the 

assignment process for entities that themselves are not required to get an LEI if they are participating 

in certain financial markets. Per the Solicitation of Interest, "[Solution Providers] must be able to provide 

LEI issuance for both a self-registration model and have the capabilities to assign LEis in cases wl';ere 

!ega/ entities don't self-register with high data quality" (SOl, Section 1!, Prerequisites, Page 4). 

15. Hov,; vJi!! the varying g!oba! regulator; bodies such as CFTC, OFR and SEC be harmonized? 

A: in case of discrepancies. the regulators wi!! collaborate among themselves and with the industry 

participants through normal regulato,.,; channels to develop consensus. 

16 ~ urhe data model ~~til! require metadata (including audit data), and should include;; but not be 

limited to, the follo~~~,ing classes: Certification data (e.g., date of last certification; name of 

certifier)" (Section 6.3, Page 21). V'lould the individual responsible for the submission or 

certification cf an entity be required to be of a c~rtain rank cr responsihHity \\'ithin the 

organization and furthermore V!I'Oti!d they be required to provide fuli contact detaHs at the point 

A: The process of data quality assurance should be articulated in the solution provider's submission. We 

are open to recommendations and wil! assess the processes the provider intends to utilize in order to 

ensure the submission/registration process is robust and a!!o~vs for the highest level of data quality. 

17. "The data mode! wi!! require metadata (including audit data), and should include, but not be 

limited to, the following classes: Certification data (e.g., date of last certification; name of 

certifier)" (Section 5.3, Page 21). 

Is there a requirement for an entity to submit limited, publically available documentation as part 

of the registration and. validation process? As a proposal before an LEI submission or update is 

precessed 2 forms of cfficia! documentation (from \~Jide rang~ng Hst of possible documents -

4 
dated within the past 3 months) is provided to the LE! Solution provider. Such document 

provision may assist greatly in ensuring accuracy whilst potentially preventing Duplication, 

Fraudj Errors, uTake DovJn" ATiacks or "Spoofing" Attacks~ 

A: Please see response to #16 

18. "The initial data mode! should require the following attributes:- Exact legal name" (Section 6.2, 

Page 20). 

a.) Particularly in non-US jurisdictions an entity may have multiple !ega! names; e.g. Nestle S.A.. 

which has !ega!ly valid alternate !lames of Nestle AG and Nest!e Ltd. in such scenarios is there 

an agreed best practice? 

b.) In relation to the above where an entity's "Exact Legal Name" is not in an accepted latinengHsh forrnat should !his he Irans!ated and the original form~I of the name be stored and 

defined as a legally valid alternate name? 

A: As stated in the requirements document. we expect the solution provider to develop a data model that 

is "based on internationally recognized standards and meets provisions required for international 

usage, including, but not limited to, address provisions (e.g., two address lines are not sufficient. postal 

codes frequently exceed 5 character); translation provision; and international standards (e.g., ISO 

Country Codes, Unicode standards). As the solution is implemented across global jurisdiction, the data 

model "should provide for the different requirements around international character sets" 

(Requirements Document, Section 6.2, Page 21). 

Specifically, please address your approach as part of your response to questions within the "Data 

Standards/Model" category (SOi, Appendix B, "Data Standards/Mode!" Section, Question 2). 

19. "The initial data model should require the following attributes:- Exact legal name" (Section 6.2, 

Page 20). In relation to the above where an entity's "Exact Legal Name" is not in an accepted 

!atin .. engHsh format should this be translated and the original fermat of the name be stored and 

defined as a !ega!!y va!id alternate name? 

A: Please see response to #1 B 

20. "The LEI must a/lot.AJ for growth in the volume of identifiers without having to reuse numbers or 

change the structure." (Section 6.1, Page 19). What is the approximate number of entities 

envisaged to be captured v¥ithin the LEI database; 2J 57 10 million? 

A: Estimates put fo!VIard by tile Linchpin Group in t11eir LEI Report "indicate that within the United States, 

this universe would total between 500.000 and 2. 000,000 entities" (Creating a Linchpin for Financial 

Data: The Need for a Legal Entity Identifier, Page 10). However, it is important to note that the 

proposed LEI solution must be built on the principles of extensibility to provide for the growth of the 

identifier as its usage expands. 

21. "The LEI should follow a !ega! entity through its life regardless of corporate actions or other 

business or structural changes." (Section 6.1, Page 19). Is there a requirement for a brief textbased event description or code to be utilized upon update e.gK "Update due to Name Change", 

"Update due to relocation of Corporate Headquarters" thus providing a level of audit 

history/traceability? 

A: Several characteristics of tl1e LEI are ideal for the identifier to be useful to a large audience. Tl1e 

proposed data model includes metadata which supports auditing and database maintenance. The 

requirements document outlines minimum metadata classes. but is not limited to them. "!nitiai!y. the 

key guiding principle as to tl1e scope of the data model is tl7at it should include the minimum number of 

data elements required to assure the "uniqueness" of each legal entity. The greater the number of data 

elements, the increased likelihood that there will be errors and delays in the application process, as 

we!! as for errors caused by a failure to update" (Requirements Document, Section 6.2, Page 21). 

5 
Hovvever, ~·ve are open to solutions t!Jet may capture t!1ese additional event descriptors, provided they 

have clear and concise definitions for each. For further information. please see section the 

,q_equirements Document (F:;?.equirements Documen(. Section 6.3 .. Page 21). 

22. "The LEI should fo!!o~AJ a legal entity through its life regardless of corporate actions or other 

business or structural changes." (Section 6.1, Page 19). Is there a requirement to capture 

additional data on significant events such bankruptcy or insolvency e.g. Event Date~ Event 

Type, Emergence from Bankruptcy? 

A: Please see response to #21 

23. The requirements document states on Page 33 "Value-added services based on the pub!ica!ly 

available database can be freely developed and commercialized by third partiesJ assuming 

tf1ese services are unbundled (i:e~j separate from) and voluntary (i.e:, not required to acce.ss and 

use LEI information). " To clarify, this vJou!d seem to indicate that any company, net just the 

LE! provider, could develop and market for-profit services. To the extent such companies need 

participate (partner} v;~ith these 3rd parties and/or charge a premium fer providing such access? 

A: Firms and 3rd party Vendors are free to use the data hovvever they see fit as the data itself does not 

11ave restrictions on reuse or redistribution. However, if firms or vendors receive data througlJ services 

beyond what is considered "basic". then premium pricing is possible. Such potential future requests for 

data vvou!d be subject to consideration and and approval by the LEI Governance Body. Per the 

requirernents docurnent, "Given expected va1ying levels of consurnption, the LEI Governance 

Committee also requires the ability to approve a reasonable fee structure for consumers requiring 

services beyond the free interface to cover the costs of such services. Such a fee structure ~vi!! be 

established to ensure the basic annual fee is kept to the lowest amount possible for LEI registrants that 

have limited financial market activity and have little or no need of services beyond obtaining an 

LEI .. . the LEI Governance Cornmittee shali conduct an independent study or engage appropriate 

experts to confirm that a fixed or other fee structure is feasi!J/e and sustainable to cover the LEI costs" 

(Requirernents Oocu:nent, Section 9. 2} Page 32). 

24. What is the expectation of ho~v quickly the LEI Service provider can recover the startup 

A" lt1/e expect that the solution provider will make this assessment as the time to recover startup costs will 

vary by proposed solution. 

25~ Given focal government data privacy issues and local data access issues does the data center 

A: There are no specific location requirements as long as "the physical location of t!Je LEI database, as 

well as the access rights to the information contained within it. must consider and comply with local 

regulations relating to data privacy and data access issues" (F~equirements Oocumen(. Section 8.2_. 

Page 30) We thus expect the solution providers to leverage their considerable international experience 

and accepted best practices to develop possible options and subrnit as part of this response. 

26. The Committee has not commented about LEI operational implementation. \''Jill it. and '..Nhen? If 

A. Implementation dates will be determined by regulatory reporting requirements as they are developed 

and finalized by the regulatory community around the globe. However. per the Solicitation of Interest, 

general expectation for issuing includes solution provider being "able to issue, register and maintain 

entity identifiers ~,;vithin 12 months11 (Requirements Document, .Section 1} Page 4). 

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27~ Hov1 many languages are required fer the support of this service? Please provide the Hst; if it is 

A: We are advocating the creation of a global LEI solution, and having multiple language functionality and 

t.he ability to use multiple character sets as necessary has been identified as critical for international 

viability. Holtvever.. no list of languages has been defined- the languages required rnay expand through 

phased global roll-out. 

2ft The SO! states the Committee's intent of "recommending and/or endorsing the solution 

provider(s) to the OFR and regulators around the globe". Has the OFR, SEC, CFTC, or any other 

regulator in the U.S. or around the globe given the Committee a specific role in the regular 

A: The regulatory community has expressed its desire for the industry to identify such a solution through a 

consensus process; the Treasury has laid out this recommendation in its initial policy statement on the 

issue. Per the Trea.suty OFR policy, nro support the Councfi in identifying connections among market 

participants and monitoring systemic risk, the Office intends to standardize Jww parties to financial 

contracts are identified in the data it co!lects on be.half of the 

Council. The Office is issuing a statement of policy regarding its preference to adopt through 

rulemaking a universal standard for identifying parties to financial contracts that is established and 

implemented by private indust(lj and other relevant stakeholders through a consensus process" (OFR 

Statetnent on Legal Entity Identification for Financial Contracts) Page 1). Our process is designed to 

deliver that recommendation to the regulatoty community. 

29: Can you deve~op further the responsibilities of the LEi Solution Provider ,,~;ith regards to 

vJcrking v1!th global regulators and the LEI GC to ful!y require and enforce self-registration? 

A · !t ~A.Ji!! be the responsibility of the regulators, the LEi Governance Body and the financial firn?s 

tl?emselves to enforce the use of the LEI as described in the Requirements document. "The success of 

the LEI solution expressly depends upon the coordination and next steps of the regulatory community 

as well as members of the global financial services industry ... The success of the LEI Solution reiies on 

regulators from every part of the world requiring the use of the same LEI standard in their rulemaking 

and reporting requirements. The consistent adoption and use of the new LEI standard will require the 

supporl of the regulators through their existing oversight and enforcement mandates" (Requirernents 

Document, Section 4, Page 14). 

30. The LEI Solution ;"Jrovit!er should take reasonable steps to ensure corporate actions are 

proactively monitored and maintained." (Section 7.2, Page 25). Where an entity has been found 

not to have updated the LEI Solution provider \:Vith the required data is there an agreed 

esca!ai!on precess by ~~Jhich an errors or omis~ions can be addressed7 particularly in 

circumstances VJhere the filing entity is un\AJilling or unable to provide revised data? 

A: Please see response to #16 

31. "The LEI Solution provider should take reasonable steps to ensure corporate actions are 

proactively monitored and maintained." (Section 7.2, Page 25). Are there penalties envisioned 

for entities tfu~t da not report ~"'!if:!: in thtJ 24-hr ~~liru:Jo~A~ and ~vhaf: authority or organization is 

responsible? 

A: Specific details around the amount and frequency of the penalties involved have not yet been defined . 

. 1-fowever, it is assumed at this time that regulators will be expected to enforce and levy the penalty 

system. The requirements document states that "the legal entity must update the relevant information 

in the LEI database .... however, the !ega/ entity can populate the data change prior to the effective date 

using the "as ~viii ben versionfng functionality" (l~equfrement~ Document, Section 7.2, Page 25). For 
additional information, please see the "Compliance" section of the Trade Associations' Requirements 

Document (Requirements Document, Section 11, Page 35). 

32. Please clarify the enforcement agency responsible to insure the following "Issuer and 

Reference Entity registration should take place as part of the 1.mdervvriting process". (Section 

7~ 1, Page 24) 

A: Agencies involved and with responsibility for enforcement will evolve as t11e mandate to use LEis 

expands through phased implementation. For a further discussion, please see the "Critical 

Dependencies" section of the Pequirements Document (Requirements Document, Section 4, Page 14). 

The requirements document states (Requirements Document, Section 7. 1, Page 24) t!1at "T!Je LEI 

Solution Provider over time shaf! work •t.tith the global regulators and the LEI governance committee to 

fully enforce self-registration". 

8 
Solicitation of 

Interest Q&A 

Responses to Questions Round 2 

I 
1. The executive summary ca!!s fer the solution providers to define their firm type in the executive 

summary. Do a!! solution providers need to fa!! into one of three types or are there additional 

options? 

A: Per the Solicitation of Interest, the core focus of this initiative is to "identify one or more solution providers 

who, individually or col!ectively, can build the LEI system capable of meeting or exceeding the expectations 

outlined in the requirerr;ents docurnent" (.SO!, .Section 1.2, Page 3}. Therefore, the focus at the current tfrne 

is actually identifying solution providers that represent at least one of the tiJree defined solution provider 

types per t.he Requirements Document (LEI Standard, LEI Issuer, LEI Facilities Manager) (Requirements 

Docurnent .Section 8.2, Page 31). 

2. The executive summar1 calls fOr a firm to specifically determine if they are in one of three 

A: See response to #1 

A: Yes. The requirements document states the need for a data standard that is recognized by an 

internationally accepted standards body Per the Requirements Document, "Th e LEI Solution should se,n,;e 

as the internationally recognized data standard for the identification of !ega! entities . provided that data 

standard includes at feast the following: Persistent, Neutral, Singular, Unique, Extensible (Scalable), 

Structurally Ffxed11 (F:r.equirements Docurnent, Section 6.11 Page 19). 

4. The stability of financial markets has far reaching implications en business beyond financial 

institutions. !s there any intention to include other stakeholders in the SO! evaluation process (e.g. 

A: The evaluation process is led by "both market participants and trade associations" (Requirements 

Document, Section 3.3, Page 8). The evaluation committee composition is balanced to ensure that 

representation across functional expertise .. firms and geographical regions. 

5. Since the SOl Selection \Viii have an impact on the financial services industry, governments and 

regulators, both domestically and globally, wil! the detail supporting the SO! selection process and 

decision be shgred pub!ic!y? Such detaH7 bcrrc\~ling from current transparency notions invc!ved in 

the government's ovJn LEI, UIC, UCI solicitation cf interests processes, ~tculd include: 

requirements, and the content of all received submissions. 

A' There are currently no plans to release the content of the solution provider submissions in public domain 

due to non-public, competitive, and proprietary information included therein. 

As to tl7e details of the evaluation process itself, a 17igl7 !eve! summary is below. Greater details as deemed 

appropriate by industf1/S LEI Steering Committee will be published upon the completion of the provider(s) 

identification process so as to allow providers to develop innovative and broad solutions. 

High Level Sum maN of the Evaluation Process: As part of the evaluation process provider submissions will 

be anonymized and assessed on prerequisites (SO!, Section !1.1 , page 4), supplier profile (SO/, Section Ill, 

page 7) and the questions detailed in Appendix B (SO!, Appendix B .. page9). Appropriate qualitative and 

quantitative measures will be applied, as agreed to by Industry's Evaluation and Steering Committees (the 

Committees), to develop a short list of solution providers such tf1at they meet/exceed requirements detailed 

in the Requirernents Document. The short-listed solution providers ~vi!! subsequently be ca!!ed for in-person 

demonstration/presentation, following which the industf1/S LEI Steering Committee will identify and 

recommend one or more solution providers to the regulator; agencies across the globe. As part of the 

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evaluation process, the Committees intenc! to engage a F?.egiona! Trade Association Group, a Regulator 

Group. and an Other International Trade Association Group to consider the short-listed solution providers 

and provide f.eedback on an advisor; basis to ensure the evaiuation considers a very broad set of 

perspectives. 

~i !f the decision is to not share the det~H supporting the SO! selection precess, pfease explain your 

reasoning fer this approach. 

A: See response to #5 

7. There are broadly held opinions in the Financial Services industrJ that the challenges facing the 

industry go wei! beyond an LEI identification solution. Does the committee intent to address other 

identification and referent~a ! data industry challenges either as part cf !he SOi process or in the 

future? 

A: The LEI initiative is solely focused on creating a solution for the "clear unambiguous identification of parties 

and counterparties involved in all financial activities" (Linchpin Group LEI Report, "Executive Summary", 

Page 3) This fundamental piece of reference data will help enable organizations to more effectively 

measure and rnanage counterparly exposure, while providing substantial operational efficiencies and 

customer service improvements to the industry" (Requirements Document. Section 3.1. Page 7). The Trade 

Association Group is not addressing other pieces of reference data at this time. 

Hence, at this time and through this current initiative, the industry's LEI Steering Committee is "looking to 

identify one or more solution providers who. individually or collectively, can build the LEI system capable of 

meeting or exceeding the requfrernents detailed in the Requirernents Document \Nfth the intent of 

recommending and/or endorsing the solution provider(s) to the o,cR and regulators around the globe" (SO!. 

Section !-2. Page 3). 

Please note however, tl7at as part of the submission, the Solution Provider must demonstrate t!Jat t!Je 

proposed solution is extensible to accommodate future requests for other identification and reference data 

needs -- "The Trade i lssociations have drafted tl?is [F~ equirements Document] ~tvith the explicit intent tl?at 

the LEI Solution is capable of expanding to meet future regulatory requirements"(Requirements Document, 

Section 4. page 14). This flexibility on behalf of the solution provider is critical to support certain data 

elements v;hich may be required by regulators as rulernaking in this area remains pending. 

Also. please note that in the future. when the industry addresses these needs. appropriate set of 

stakeholders wi!! be engaged to ensure right set of requirernents are developed and agreed to. 

8. Regarding the LEI operational implementation, is it the ultimate intention of the committee to enter 

into a contractual agreement on beha!f of the industry with a standards body and/or solution 

response. 

A: As discussed in the .Solicitation of Interest document, the focus of the current initiative is on "recommending 

and/or encforsing t11e solution provider(s) to til e OFR and regulators around the globe" (SO!, Section 1-2, 

Page 3) The Trade Association Group will not enter into a contract(s) with the LEI solution provider(s) This 

is not our role. The mandate for use of the LEI ~vi!! carne from the global regulator; cornrnunity, countr; by 

country, and firms vvHh regulatory reporting requirements ¥Viii then contract ~,.,./ith the LEI solution provider(s) 

to obtain an LEi. 

9. Question #3 in the "Data ~Jiodel" section of Appendix 8 of the SOl states "Exp!ain ho\AJ the proposed 

data standards v.till adhere to the principles detailed in the business requirements document." 

Specifically, \ft~hich pr~ncipies are you referring to? 

A: Per the Requirements Document's "Data Model" section, the principles tflat are being referred to include 

identifier aspects as outlined in Section 6.1. Per the Requirements Document. "The LEI Solution should 

serve as the internationally recognized data standard for the identification of legal entities, provided that 
data standard includes at least the following: Persistent. Neutral, Singular. Unique. Extensible (Scalable). 

Structura!!y Fixed" (Pequirements Document, Section 6.1, Page 19). 

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