The Regulatory Oversight Committee (ROC) of the Global LEI System (GLEIS) has published a consultation paper proposing that ID issuance be extended to international branches. The ROC proposes the following conditions:
- The branch must be international eg. located in a separate jurisdiction from that of the head office. The usual dependence distinction between branch and subsidiary is applied. Only one LEI would be issued per host jurisdiction, irrespective of the actual number of establishments.
- The branch must be registered in a publicly accessible local business registry or local regulatory register.
- The branch’s head office must already have an LEI
The paper notes the complications attendant upon the dual registration of a single legal “person”, but reminds that this may be required by the reporting regulations of a host jurisdiction. As with “senior” LEI’s, a branch’s compulsory registration in the GLEIS will be decided by the relevant host or headquarters national regulator; issuance will similarly be controlled by the relevant LOU. The branch LEI (BLEI ?) would contain the same reference data as its senior sibling, with the difference that either the “LegalForm” or “AssociatedEntity” data element would be modified to create an association between HQ and its branch. The consultation contains a questionnaire to guide responses, which must be received by COB 16 November 2015.
The inclusion of branches in the GLEIS is likely to garner broad support, it was slightly anomalous that they did not form part of the original scheme. However, the proposal will do little to answer the fairly dismal take-up statistics of the scheme as a whole, compounded by a high subsequent dropout/ failure to renew rate.Contact Us