February 19, 2019

February 19, 2019

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February 18, 2019

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UK Financial Conduct Authority (FCA) Requirement for Legal Entity Identifiers

On November 7, the UK Financial Conduct Authority (FCA) has confirmed that it will require all financial institutions conducting business in or from the United Kingdom to have a Legal Entity Identification (LEI). This announcement comes some nine months after the European Banking Authority (EBA) announced that it supports the adoption of the LEI system, aimed at achieving a unique, worldwide identification of parties to financial transactions. The LEI system is not globally operational yet, but the EBA has already recommended that European Union regulators use LEIs when providing supervisory information to the EBA, and that firms use LEIs in their respective templates under supervisory reporting. 

The FCA has announced that it expects all relevant firms to obtain their LEIs from the London Stock Exchange and submit them to the FCA by December 31 at the latest. The FCA has explained that firms or groups that are required to report to the FCA consolidated basis will need to obtain LEIs for all relevant group entities on which information is required by the FCA, including the reporting firm’s parent company. Once LEIs have been obtained, the reporting firm is required to submit them (and for group entities, if applicable) to the FCA immediately via the FCA’s survey tool here, and to use the LEIs in all applicable FCA reporting conducted from the first reporting reference date in 2015. 

Instructions on obtaining LEI from the LSE can be found here

For the EBA’s announcement please click here

©2019 Katten Muchin Rosenman LLP


About this Author

Neil Robson, private equity fund managers counselor, Katten Law Firm, London

Neil Robson, a regulatory and compliance partner with Katten Muchin Rosenman LLP, focuses his practice on counseling hedge and private equity fund managers and other investment advisers on operational, regulatory and compliance issues. He regularly addresses Financial Conduct Authority (FCA) and EU authorization and compliance under both the EU Alternative Investment Fund Managers Directive (AIFM Directive) and MiFID, cross-border issues in the financial services sector, market abuse, anti-money laundering and regulatory capital requirements, formations and buyouts of...