The Federal Reserve has decided that BHCs, foreign banking organizations (FBOs), and other entities under its jurisdiction should use the globally-adopted legal entity identifier (LEI) in an array of regulatory reports.  LEIs permit both banking organizations and regulators to map exposures by legal entities (other than branches) both within a single financial conglomerate and across the financial system.  Importantly, the FRB rules do not mandate use of LEIs, but rather their inclusion in reports when they have been obtained. The FRB will thus be better able to see which large banking organizations are moving as promised on commitments to use LEIs and press them where necessary without burdening smaller institutions less likely to adopt LEIs or, perhaps, to need them to track their own structures and exposures.  The forms on which LEIs would be noted are disclosed, marking public counterparties with such specificity that some fear release of proprietary data – a problem of unique concern in the U.S. due to the considerably more transparent nature of its public-reporting protocols.

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