As discussed in a prior client alert, the Global LEI Foundation (GLEIF) recently issued guidance stating that all GMEI Utility users are required to verify that users requesting registrations and/or renewals have the proper authority to transact on behalf of their legal entity. The new verification requirement applies to all swap market participants that obtain and renew their legal entity identifiers (LEIs) from GMEI Utility.
This guidance was recently finalized, with the following implementation timeline:
- Week of August 5 – Renewals only
- Week of August 12 – New registrations
- Week of August 19 – All registrations and renewals, including Fast Track records
An authorization form will be published on http://www.gmeiutility.org/ on August 5, 2019, and it is expected to be the same or substantially similar to this draft verification form previously published by DTCC. The form is intended to verify that users requesting LEI registrations or renewals have proper organizational authority. It includes basic biographical information about the authorized person or, if a third party is authorized, the authorized company. Once submitted to the GMEI Utility, the form will be verified in order to establish that the appropriate authority exists.
As noted previously, the draft verification form requires that users print the authorization on company letterhead. This is an administrative burden that will likely not be eliminated from the final form. While many clients rely on DTCC to obtain LEIs on behalf of their customers, we understand that Bloomberg LEI does not have the letterhead requirement, and clients may consider using this service as an alternative.
Please contact Alec Fraser or Cheryl L. Isaac with any questions on this new compliance obligation.