Comment Text:
The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide you with its comments on the request for information, ‘Project KISS’ published in May 2017.
GLEIF recommends the use of the Legal Entity Identifier (LEI) as an important foundation to reduce regulatory burdens and costs in the markets and functions that the Commodity and Futures Trading Commission (CFTC) oversees. Specifically for Project KISS, the LEI would produce benefits in the following areas covered by the project – Registration, Reporting, Clearing and Executing.
The LEI enables clear and unique identification of legal entities engaging in financial transactions.
A key feature that distinguishes the LEI from other identifiers is the obligation of legal entities that have obtained an LEI to renew it regularly. Renewal means that the LEI reference data related to the registering entity is re-validated and quality assured against third party sources. The LEI could play an important role in reducing costs for obtaining reference data linked to legal entities. By introducing the LEI as general identifier, all data vendors would include the LEI with their products, meaning much reduced costs for mapping different content assets from different providers as well as more transparency in sourcing decisions. Both the public and the private sector would benefit from these gains.
The LEI already is present in the area of Reporting required by CFTC Rules (Parts 15, 17, 18 and 20) and for Swap Data Record Keeping and Reporting Rule (Part 45). The Commission also continues to prioritize the enforcement of reporting violations: ‘Care should be taken to ensure that each LEI is not lapsed, retired, or cancelled. LEI renewals may be enforced in the future.’
