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MRA backs mandating LEIs at beneficial account‑owner level, adds roundtable sequencing
Summary
The committee approved a subcommittee recommendation to require Legal Entity Identifiers (LEIs) at the beneficial account‑owner level for DCO daily reporting, but amended the language to host a roundtable and footnote subcommittee support for removing the 'where available' clause before regulatory change.
The Market Risk Advisory Committee voted to adopt a recommendation urging the Commission to move toward requiring Legal Entity Identifiers (LEIs) for beneficial account owners in DCO daily reporting, subject to an implementation roundtable.
Subcommittee speakers described the LEI as a data standard that substantially improves the ability to trace exposures and aggregate counterparty positions across legal entities. The proposal would align the U.S. reporting framework with global practices and remove ambiguity introduced by the current 'where available' phrasing in Part 39, which can leave DCOs unable to identify ultimate beneficial owners when LEIs are not voluntarily provided.
Several participants—particularly FCMs and industry trade groups—urged caution about operational burdens for retail and small end users, the cost and administrative responsibility of obtaining LEIs, and the need for clear governance so owners and controllers are responsible for registration. In response, the committee amended the recommendation: it will host a roundtable (IMRA‑led, with Commission participation encouraged) to discuss sequencing, impacts on retail participants, and transitional arrangements. The amendment will be footnoted to reflect that the subcommittee had supported removing the 'where available' language, but full removal will be revisited after the roundtable.
The amendment passed on a roll call (18 yes / 2 no / 5 abstain); the amended recommendation then passed (21 yes / 0 no / 4 abstain). The committee will forward the amended recommendation to the Commission and document the range of member views in the submission record.
