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What is a LEI?

Short, relevant history

The Legal Entity Identifier (LEI) crystallizes complex legal ownership data into a 20-character, machine-readable code.

LEIs came into play after the United States housing crisis. The Dodd-Frank Act fresh minted the Consumer Financial Protection Bureau (CFPB). Clear, unique institutional IDs were on its agenda.

Technical development was led by the International Organization for Standardization (ISO). The LEI is prized for modern transactional reporting due to an inherent open-source and non-proprietary nature. And with functional administration by a G-20 backed consortium, expect its usage to grow as the company identification number of choice.

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Do We Need a LEI?

📊 The simple answer is yes

The CFPB has regulatory power to make changes in reportable HMDA data. Regulation C mandates assigning a Universal Loan Identifier (ULI) which:

(A) Begins with the financial institution's Legal Entity Identifier (LEI) that is issued by:
(1) A utility endorsed by the LEI Regulatory Oversight Committee; or
(2) A utility endorsed or otherwise governed by the Global LEI Foundation (GLEIF) (or any successor of the GLEIF) after the GLEIF assumes operational governance of the global LEI system.

You must wield a dual-sword. No LEI, no ULI. Together, these data points ID the institution which originates a loan and any proceeding transaction engaged in with that product.

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The Final Rule is in effect as of January 1, 2018. So in order to be in 100% compliance for 2019 and beyond, HMDA reporters will need to have a LEI.