ESMA published yesterday an update of its Question and Answers (Q&A) on EMIR where amongst others it clarifies the use of Legal Entity Identifiers (LEI) for the purpose of trade reporting to trade repositories. In TR section, Question 10, ESMA clarifies that in order to identify counterparties "a pre-LEI issued by any of the endorsed pre-LOUs (Local Operating Units) of the Global Legal Entity Identifier System" can be used.

Currently there are 3 pre-LOUS that have been endorsed by ROC (WM Datenservice, INSEE and CICI utility) in order to provide pre -LEIs, which will be available for reporting to any regulator that has assented to the ROC charter and that provides for pre-LEIs in their own transaction reporting rules. This will include trade repositories registered with the Monetary Authority of Singapore, as well as trade repositories registered with the European Securities and Markets Authority, the Australian Securities & Investment Commission and various Canadian provincial regulators in 2014. Hong Kong’s trade repository will feature pre-LEIs in OTC derivatives trade reporting as well.

Especially in the case of CICI utility, its endorsement as a pre- LOU for issuing GLEIs, comes as a relief for many European based counterparties which already had an uncertified CICI number, as a result of a 3rd party registration and were waiting for European Regulators' decision as to whether they would accept CICI numbers as pre-LEIs for reporting under EMIR.

Not issued a LEI yet? You now have 3 (globally accepted) options available…..

Maria L.