One of the lessons learnt from the global financial crisis (GFC) in 2007-2008 was that early threat detection is essential to risk mitigation and crisis prevention. It became evident to regulators that effective detection was hindered by the fact that financial institutions around the world did not have a single, 任何金融交易的共同身份, 这使得识别交易对手并因此计算风险暴露变得具有挑战性.
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接下来发生了什么?
The 法律 Entity Identifier (LEI) system was among the various financial reforms launched in response to the GFC to promote stability and build flexibility within the financial markets. 作为统一的监管报告数据元素于2011年推出, with the added benefit of helping firms enhance their internal risk 管理ment system through the collection, 标准化, 以及报告数据的汇总, LEI是特定的, 20-digit alphanumeric identification code that was set up to uniquely and accurately recognise entities involved in a financial transaction.
申请lei是一个简单的过程. 作为LEI系统的一部分, established Local operating units (LOUs) are tasked with issuing and maintaining LEIs while the Global 法律 Entity Identifier Foundation (GLEIF) provides oversight on the quality, 完整性, LEI数据的值. LEI注册很简单, 采用LEI作为全球标准标识符来降低所有级别的风险-公司, 国家, 工业和全球-正在考虑之中.
现在?
The LEI was created to be the global standard identifier for regulatory reporting but its founding principles had always envisioned is use beyond this use case. 除了风险管理, an LEI can minimise the number of touchpoints across the trade lifecycle to expedite the completion of a trade. 通过使用LEI作为参考数据, it can help firms supplement their “Know Your Customer” process to facilitate client onboarding, 为公司提供现有和新客户的快速和全面的快照.
使用在交易生命周期早期引入的LEI数据, firms can also efficiently match and confirm trade details between counterparties to increase operational efficiency and reduce time spent on data reconciliation. And when an LEI is linked to a central database of standing settlement instructions (SSIs), firms can streamline 帖子-trade processing by pairing transactions with counterparties to advance to settlement.
The merit of linking an LEI to SSIs is further emphasised in a report dated April 2022, “描绘后贸易时代的未来”, that was developed by members of the task force initiated by the Bank of England (BOE) and the Financial Conduct Authority (FCA). 报告强调，尽管LEI经常用于衍生品交易, 现金交易的情况下, lei使用得太少也太迟，而ssi则经常手工交换, 导致高成本和贸易失败.
The recommendation offered in the report was to create a new 帖子-trade industry leadership group comprised of willing participants from across the industry to work together to develop and promote a set of best practices on sharing LEIs early in trade-lifecycles and to create efficient, 通信ssi的电子过程.
在亚洲, LEIs are increasingly being used in markets like Malaysia for payment transactions to streamline the online payment process as well as enable fast and accurate identity 管理ment.
越来越多的监管要求会推动进一步采用吗?
根据GLEIF, LEI系统的管理主体, 目前，全球已发行的活跃lei超过200万份, 其中亚洲约占总活跃用户数的11%. The question remains whether ongoing changes in regulatory requirements could continue to expand application of the LEI.
到目前为止, 欧洲当局, 与全球金融危机之后的原始专题审查保持一致, 已经实施了法规要求. 经常提到的“无LEI”, no trade” is an extraterritorial prerequisite of the Markets in Financial Instruments Directive II (MiFID II) that necessitates the inclusion of LEI data to recognise any counterparty – in 欧洲 or elsewhere – involved in domestic and cross-border trades.
欧洲市场基础设施法规(EMIR), 证券融资交易条例(SFTR), 另类投资基金经理指引(AIFMD), and Solvency II are some of the other 欧洲an regulations that also stipulate LEI requirements in trade and transaction reporting.
在美国, the LEI has both been mandated and endorsed for the reporting of over-the-counter (OTC) derivatives contracts to financial regulatory authorities. 在香港, an LEI is required for derivatives reporting as stipulated by the Hong Kong Monetary Authority (HKMA).
与澳大利亚的各种监管机构合作, 日本, 新加坡, 欧洲, and the US working on rewriting their specific rules to drive global data harmonization in OTC derivatives trade reporting, the CPMI-IOSCO working group on harmonisation has proposed that LEI data along with Unique Transaction Identifiers (UTI) and Unique Product Identifiers (UPI) be adopted in the regulatory rewrites to facilitate global aggregation and analysis of reported trade data.
The combined data – based on common data standards – would enable trade repositories to collect and maintain quality data needed to monitor, 管理, 降低系统风险.
未来的愿景是什么?
随着LEI信息在金融公司中变得越来越普遍, the industry gradually moves closer to the financial reform agenda of attaining a more thorough view of risk review and assessment across asset classes and multiple jurisdictions.
对于不受域外监管指令影响的公司, using LEI as the global data standard eliminates the need for multiple identifiers or unifies other reference data used to identify counterparties. Doing so will bring about a more streamlined operational approach and reduce the risk of linking the wrong entity to a financial transaction.
As the “描绘后贸易时代的未来” report put forth: solutions need to be more standardised and more interoperable, 利用单一的, centralised repository to track parties in a financial transaction will enable greater transparency, 削减成本, 并降低行业的运营风险.
本文最初发表于 亚洲监管 2022年10月28日.