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OFR_2016_Financial-Stability-Report

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The LEI is required in only a few U.S. market segments, such as derivatives<br />

data recordkeeping and reporting. Industry adoption has been largely limited<br />

to where regulators require its use (see Figure 69). The <strong>OFR</strong> backs universal<br />

adoption of the LEI in all financial markets and plans to mandate its use in its<br />

data collections.<br />

European regulators have more broadly mandated the LEI for financial transactions<br />

in markets beyond derivatives. Under new rules known as Markets in<br />

<strong>Financial</strong> Instruments Regulation (MiFIR), trades in equities, bonds, and other<br />

instruments will require LEIs for all parties by January 2018 (see King, <strong>2016</strong>).<br />

The LEI will be increasingly valuable as use grows. The LEI system will add<br />

information about the parent and subsidiaries of each entity, to be phased in<br />

beginning in late <strong>2016</strong> (see LEIROC, <strong>2016</strong>). This information will help fulfill the<br />

promise of the LEI. The system will serve as an additional tool to analyze the<br />

complex structures of large financial services companies and their holdings.<br />

Figure 69. U.S. Agencies Requiring or Planning to Require Use of the Legal Entity Identifier<br />

Agency Rule Companies affected<br />

Commodity Futures Trading<br />

Commission<br />

Consumer <strong>Financial</strong> Protection Bureau<br />

Department of the Treasury<br />

Federal Energy Regulatory<br />

Commission<br />

Securities and Exchange Commission<br />

Swap Data Recordkeeping and <strong>Report</strong>ing<br />

Requirements<br />

Trade Options<br />

Home Mortgage Disclosure<br />

(Regulation C) (Effective January 2018)<br />

Qualified <strong>Financial</strong> Contracts Recordkeeping<br />

Related to Orderly Liquidation<br />

Authority (Effective Dec. 30, <strong>2016</strong>)<br />

Data Collection for Analytics and Surveillance<br />

and Market-Based Rate<br />

Purposes (Effective date to be<br />

determined)<br />

Regulation SBSR – <strong>Report</strong>ing and<br />

Dissemination of Security-Based Swap<br />

Information (Effective date to be determined)<br />

Swap counterparties<br />

Swap dealers that are trade option<br />

counterparties<br />

Banks and financial entities<br />

<strong>Financial</strong> companies defined in the<br />

rule as “records entity”<br />

Market-based rate sellers and<br />

entities trading virtual products<br />

or holding financial transmission<br />

rights in the organized wholesale<br />

electric markets<br />

Counterparties in securitybased<br />

swaps reported to a registered<br />

swap repository<br />

Note: Under other rules, a variety of agencies request that reporting entities use the legal entity identifier as an identifier if they<br />

already have one, or allow optional use of the identifier.<br />

Source: <strong>OFR</strong> analysis<br />

Key Threats to <strong>Financial</strong> <strong>Stability</strong> 81

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