GFMA, IIAC, IIF and ISDA Submit Comments to LEI ROC in Response to Consultation Paper on Including Data on Branches in the Global LEI System
Global Financial Markets Association (GFMA), Investment Industry Association of Canada (IIAC), The Institute of International Finance (IIF) and International Swaps and Derivatives
Association, Inc. (ISDA) provide response to the Legal Entity Identifier Regulatory Oversight Committee’s (ROC) “Consultation Document: Including data on branches in the Global LEI System.” Overall, the associations support the ROC’s proposal to incorporate an identification approach for branches into the Global LEI System (GLEIS) as there is a need for such an identifier. The associations strongly agree there is a need for a global, standardized approach for the regulatory reporting of branches and branch activity and believe the LEI system provides a good operational structure for this purpose. While the associations support new guidance for a branch identifier, they have several concerns with the approach proposed by the ROC and make recommendations for addressing those concerns in the letter.