Q1:What is LEI?
Ans:The Legal Entity Identifier (LEI) is a unified global reference code used in identifying every legal entity participating directly or indirectly in securities transactions in the market.
Q2:Who are to register for LEI?
All entities that issue equity, debt or other securities for other capital structures.
All entities listed on an Exchange.
All entities that trade stock or debt.
Investment vehicles, including mutual funds, pension funds and alternative investment vehicles constituted as corporate entities or collective investment agreements (including umbrella funds as well as funds under umbrella structure, hedge funds, private equities, etc).
All entities under the purview of a financial regulator and their affiliates, subsidiaries and holding companies.
Counterparties (buy side and sell side) to financial transactions.
Q3a: What are the particulars required for registration?
Official name of the entity.
Name of the business registration.
Identity number of the entity (RC Number ? if applicable).
Legal address of entity.
Date the LEI was first assigned.
Date of last update.
Date of expiry.
Reason for expiry etc.
Clearing House Number (CHN).
Q3b: What are the particulars of the contact persons needed?
Q4: What is the difference between LEI and ISIN (International Securities Identification Numbers)?
Ans: LEI identifies all direct or indirect participants in securities dealings, while ISIN code identifies local symbols internationally.
Q5: Is the organization in charge of the LEI very new (organization only started in January 2013 and the list of regulators only finalized in Nov 2014)?
Ans:Yes and it is a directive from G20.
Q6:Is there a time frame to register?
Ans: Yes but SEC will announce the cut-off date soon.
Q7: What are the implications of late registration?
Ans: The Entity may face sanction and their access to our local markets can be denied.
Q8: How can I know that a Global custodian already has an LEI?
Ans: Only the local Custodian can confirm that from the Global Custodian or from the Investor.
Q9: Is it the global custodian that requires the LEI
or is it the underlying client that requires the LEI?
i.e. Who is deemed the active participant here?
Ans: The account holder at CSCS (Legal owner) is expected to register as well as the beneficial owner.
Q10: Is LEI now mandatory from a regulatory perspective?
If yes, what was the effective date for this becoming mandatory?
Ans: Yes, LEI is mandatory from the Regulatory perspective, effective from December, 2014. Cut-off date is yet to be determined.
Q11: Can local custodian register her clients online for the LEI via the CSCS portal?
Q12: Can the global custodian pay the CSCS directly for the LEI?
Ans: No, we receive such payment from the local Custodian who acts on their behalf.
Q13: Considering that Custodian clients? assets are held in omnibus accounts at the CSCS,
registered in the name of the custodian, what is the use of their signing for the LEIs?
Ans: LEI identifies the legal and beneficial owners separately.
Q14: Please confirm if the requirement is for underlying clients and
not global custodians or for both.
Ans: For both.
Q15: Please confirm if investors are free to apply for such LEI through the LOU (Local Operating Unit) of their choice
(e.g. LSE if they so prefer)
Ans: Yes. Through LOU of their choice.
Q16: If investors are to request for an LEI directly from the CSCS through its website,
how will the payment (in NGN) be facilitated?
Ans: They are to pay through their local Custodian.
Q17: Please advise what other information is required next to the LEIs. E.g Account number.
Ans: Clearing House number i.e. CHN is required or ISIN number if it is a quoted company
Q18: How is the information stored at CSCS?
Ans: Stored in Tables
Q19: E-mail is not considered as a valid means of instruction.
Please advise what alternate instruction means you would accept.
Ans: CSCS data exchange portal, SWIFT, direct submission of letter.
Q20: Will the LEIs be connected to CCIs in any way? If so, please advise how.
Ans: No, for now.
Q21: Is there a public register of LEIs in existence that can be used by the CSCS?
Ans: There is no public register for now. What exists is the Global register at Switzerland, the Headquarter of Global Legal Entity Identifier Forum office, an agent of G20 for this initiative. So, as we assign LEI, we forward same to them for global update, same applies to other jurisdictions. The register will be made available soon.
Q23: Will LEIs have to be included in future transaction instructions?
Ans: Yes, for information only and such should be communicated to CSCS once if it was got from other jurisdictions.