On December 20th, 2017 ESMA issued a statement announcing steps intended to smooth the introduction of MiFID II’s legal entity identifier (LEI) requirements. Some of the news headlines regarding the statement might lead you to believe that all of MiFID II’s LEI requirements have been delayed six months, but that’s not the case. Additionally, the delayed requirements have conditions attached. If you are actively involved in LEI data management or are working on MiFID II implementation, it’s worth reading ESMA’s brief, two-page statement.
“No LEI, No Trade” captures the essence of MiFID II’s legal entity identifier (LEI) requirements. You may have seen this phrase in a financial markets publication or blog post. Its use is invariably accompanied by a call for European market participants to apply for a legal entity identifier in advance of the January 3rd go-live. Please heed this call. If your firm or fund doesn’t have an LEI by that date, you won’t be able to trade in European markets.