ABA welcomed the Federal Reserve’s proposal to require banking organizations to include their current 20-digit legal entity identifiers on several regulatory forms — namely, FR Y-6, FR Y-7 and FR Y-10. “[T]he continued expansion of LEI’s use in both markets and reporting is a positive step,” ABA said, and the Fed’s proposal “is a conservative expansion in mandated LEI reporting that does not present major implementation concerns.”
However, ABA urged the Fed to keep in mind the costs and implementation challenges associated with expanded LEI reporting. For example, ABA asked the Fed to make the deadline for one-time submission of LEI data concurrent with the filing deadlines for FR Y-6 and FR Y-7.
Read the letter.