The Office of Financial Research (OFR) has begun the work authorized for it in the Dodd-Frank Act, seeking views on ways to track financial transactions by legal entity.  OFR has decided that this is warranted in general, seeking views on how these identifiers should be determined and by whom, not on whether this should be done at all.  The concept has significant implications not just for firms that might seek to issue or use such identifiers, but also for regulators seeking better ways to ensure they know at the start of a transaction who is responsible for executing or honoring it.  Debate about the degree to which specific obligations should be housed in clearly-identifiable subsidiaries may be affected by OFR’s proposal, as the more clearly an institution is identified, the less complex its operations may be even if housed in diverse branches far from a home office.

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