ESMA and FCA Statements on LEIs under MiFIR
Please note that ESMA and the FCA have issued statements on the use of LEIs for MiFIR go-live.
"For a temporary period investment firms may provide a service triggering the obligation to submit a transaction report to the client, from which it did not previously obtain an LEI code, under the condition that before providing such service the investment firm obtains the necessary documentation from this client to apply for an LEI code on his behalf.
The investment firm will need to immediately apply for the issuance of the LEI on behalf of the client. Once the relevant LEI has been obtained, the investment firm should submit its transaction report."
To facilitate this change, UnaVista will temporarily to disable the validation on the trade date being on or before the LEI registration date for the following fields:
- Buyer Identification Code
- Buyer Decision Maker Code
- Seller Identification Code
- Seller Decision Maker Code
We are aware that different NCAs may be implementing this change at different dates before or after go-live and we would recommend that you consult with your home state NCA on their reporting requirements in relation to this change. If your NCA implements this change after 3 January, there is a possibility that a report accepted by UnaVista will be rejected by your NCA.