A little bit more than a footnote for pre-LOUs
On 26 August 2014, the Regulatory Oversight Committee (ROC) published an updated version of the Principles to be observed by pre-LOUs that wish to integrate into the Interim Global Legal Entity Identifier System (GLEIS).
One generous footnote was added, which provides further clarification on the mandatory conditions for endorsement:
1. Adherence to the Principles as specified in this note of July 27 2013,
2. Application of the Common Data format for pre-LOUs (see notes on the ROC website of 19 June 2014 and 24 February 2014
(http://www.leiroc.org/publications/gls/lou_20140620_2.pdf ,
http://www.leiroc.org/publications/gls/lou_20140620.pdf and
http://www.leiroc.org/publications/gls/lou_20140224.pdf)
3. The further conditions set out in the initial endorsement note
(http://www.leiroc.org/publications/gls/lou_20131003.pdf ) and all subsequent endorsement notes.
4. Agreement to contribute to the funding requirements of the GLEIF in line with the G20 endorsed FSB recommendations (http://www.leiroc.org/publications/gls/gleif_20140629_2.pdf )
5. The further guidance on portability published by the ROC on 24 August 2014
http://www.leiroc.org/publications/gls/lou_20140824.pdf
6. Additional guidance from the ROC, as and when this is provided.
As of 30 June 2014, there were 28 pre-LOUs, 16 of which were endorsed by the ROC to issue globally accepted LEIs and 12 of which had been allocated prefixes to support their operational planning and development.
The purpose of this latest tweak is to improve harmonisation between pre-LOUs, a prerequisite before full operational deployment can be achieved. The Global Legal Entity Identifier Foundation (GLEIF) was recently created under Swiss Law, which is expected to take over ultimate supervision of the LEIs and ensure uniform global operational standards.
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