Response to consultation on Draft Recommendation on the use of Legal Entity Identifier (LEI)

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Please, provide your feedback on the proposed timeline and the proposal of having less tight deadlines for banks not included in the EBA sample.

We would suggest the EBA consider phasing in what entities will require a LEI. For many firms there will be a very high number of entities needing an identifier, many of which will rarely (if ever) actually be involved in activity that needs reporting. It would help smooth the implementation of the LEI of some thought could be given to how the LEI could be prioritised for entities that will need the code from the go-live date, and allow the others to be assigned a code at a later date.

Based on factors such as materiality, business activity and status (e.g. dormant or non- trading), it would seem disproportionate to have to register all entities to meet FINREP deadlines or indeed to register them at all. In particular, FINREP template 40 requires an entity-by-entity breakdown of the group structure, including the LEI Code. We would be concerned if this meant there was a requirement for all subsidiaries of a firm to register for an LEI code to meet that requirement alone. A number of our members have many hundreds of subsidiaries, most of which would not otherwise need to apply for a LEI.

This will take some of the pressure of the LOUs, and provide firms with a better opportunity to complete their internal on-boarding and system updates.

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Name of organisation

British Bankers' Association