Comment Letter Responding to OFR’s Policy Statement and Request for Comments on a Uniform System of Legal Entity Identification for Financial Contracts

MFA, along with several other financial services trade associations, filed a joint comment letter in response to the Office of Financial Researchs (OFR) Policy Statement and request for comments on developing a uniform system of Legal Entity Identification for Financial Contracts (LEIs). In the joint letter, the trade associations expressed their willingness to work with OFR in developing a uniform LEI system. In the letter, the associations also listed several important principles that should be considered in developing an LEI system, including: (i) the entity responsible for issuing LEIs should be a non-profit, with stable funding and a transparent process; (ii) Treasury should clearly define which entities need to obtain an LEI; (iii) Treasury should consider a self-registration model; (iv) the characteristics of an LEI should be neutral; and (v) the data elements for the LEI process need to be carefully considered, particularly with respect to individuals, pooled investment vehicles and institutional investors.