With implementation of EMIR weeks away, the production time for mandatory pre-legal entity identifiers varies between the pre-local operating units that issue the codes and depends on a number of factors
Pre-local operating units (pre-LOUs) are preparing for an increase in pre-legal entity identifier (pre-LEI) registrations in the final weeks before the identifiers are required for trade reporting as part of the European Market Infrastructure Regulation (EMIR). However, the waiting time for pre-LEI codes ranges from 24 hours to several weeks, depending on the pre-LOU chosen, the number of entities submitted in a single request and other factors.
Market participants have expressed concern that pre-LOUs will become inundated with requests for pre-LEIs in the weeks before EMIR trade reporting requirements come into effect for exchange-traded futures, options and over-the-counter derivatives trades in Europe on February 12. Pre-LOUs have increased their teams and introduced process and technology changes to deal with anticipated surges in demand. However, the turnaround time for new pre-LEIs varies between the pre-LOUs and depends on a number of factors.
DTCC and Swift
More than 106,000 pre-LEIs have been registered with the CFTC Interim Compliant Identifier (CICI) utility operated by the Depository Trust and Clearing Corporation (DTCC) and Swift. According to Ron Jordan, DTCC's New York-based managing director and chief data officer, the turnaround time for its pre-LEIs is one to three days, depending on whether the registration is submitted through the CICI utility portal—the fastest method—or through the bulk file process, which is slower.
Jordan expects the volume of CICI registrations to continue growing in the coming weeks, but does not believe there will be a "significant increase" in turnaround time for new codes.
"The CICI operating model is flexible, and we have already bolstered our validation team in anticipation of increased demand. We are confident we will be properly staffed to handle any uptick," says Jordan, who points out the CICI utility has experience of handling surges in demand, as it was the only pre-LOU in operation when CFTC reporting requirements came into effect last year.
More than 23,500 pre-LEIs have been registered with the General Entity Identifier (GEI) utility operated by Germany's WM Datenservice. Uwe Meyer, Frankfurt-based manager at WM Datenservice, says it currently only issues its pre-LEIs after it has received payment and completed all validation checks, and the turnaround therefore ranges from three days to three weeks.
According to Meyer, the turnaround time depends on factors such as the domicile of the entity and type of entity, which affect the validation checks needed. He explains that validating data submitted by German entities is "less work intensive" for WM
Meyer says WM Datenservice will probably introduce a new "pending issue" status in the coming weeks, which it will use when all duplication checks and the core validation checks have been completed. Meyer says this will enable WM Datenservice to shorten the turnaround time "significantly." If necessary, staff from others parts of WM Datenservice may also be added to the pre-LEI project.
More than 7,500 LEIs have been registered with France's Institut National de la Statistique et des Etudes Economiques (Insee), which only accepts registrations from French entities. Pierrette Schuhl, deputy head of Insee's directories department, says it issues codes within seven to 10 days of receiving a request. She explains the number of staff working on the pre-LEI project has been increased and Insee expects to maintain its current turnaround time if the volume of registrations grows in the coming weeks.
More than 4,000 pre-LEIs have been registered with the pre-LOU operated by the London Stock Exchange (LSE). Emma Kalliomaki, the LSE's London-based head of SEDOL masterfile, says "it is difficult to define exactly" how long entities must wait to receive one of its pre-LEIs, as the time varies from case to case. However, she adds, "typically turnaround time is days rather than weeks." Kalliomaki says the LSE has increased its pre-LEI team and hopes to maintain its current turnaround times in the coming weeks.
Dutch Chamber of Commerce
More than 2,400 pre-LEIs have been registered with the Dutch Chamber of Commerce, which only accepts registrations from entities that are registered in the Dutch Business Register. Freddy Keij, Utrecht-based business owner of the LOU task, says the turnaround time for pre-LEI codes is "about 10 days," explaining that payments must be received before the pre-LEI is issued. The Dutch Chamber of Commerce has increased the number of staff working on its pre-LOU from four to eight, but Keij says "it will take a few days longer than normal" to receive a pre-LEI if the number of requests increases in the coming weeks.
Irish Stock Exchange
More than 800 pre-LEIs have been registered with the Irish Stock Exchange (ISE). Brian Healy, the ISE's Dublin-based director of traded markets, development, operations, says entities usually receive their codes within one week, but it can take longer for bulk requests or if an application is subject to a query. Healy says the ISE has increased its pre-LEI issuance team and has the option of drawing on its National Numbering Agency staff. As a result, it expects to maintain its current turnaround times.
Krajowy Depozyt Papierów Wartościowych
More than 500 pre-LEIs have been registered with Poland's Krajowy Depozyt Papierów Wartościowych (KDPW), which accepts registrations from entities in the European Economic Area and Switzerland. Iwona Sroka, Warsaw-based chief executive officer of KDPW, says when all required information is submitted, it can issue pre-LEIs in 2–3 days. Sroka says KDPW is ready for an "increased number of applications" and "will deploy all competent personnel to verify submitted applications".
Turkey's Takasbank has issued 15 pre-LEIs. Necla Küçükçolak, Istanbul-based international markets manager at Takasbank, says local entities currently receive their pre-LEI code within two business days, while the turnaround time for foreign entities is three to 10 days. There are two to three people working on Takasbank's pre-LEI project at present. This may be increased if demand grows. Takasbank is planning to launch an online portal for registrations at the end of the month and expects to maintain its current turnaround times for issuing pre-LEIs.
National Settlement Depository
Russia's National Settlement Depository (NSD) has issued three pre-LEIs. Eddie Astanin, chairman of the NSD's executive board, says the NSD is contractually bound to issue pre-LEIs within five business days of receiving payment, but in reality issues them within two days. He says the number of pre-LEI registrations is increasing at a "predictable speed" and the NSD will continue to honour its commitment to a five-day turnaround.