Global Legal Entity Identifier Update for ACSDA General Assembly April 4, 2014

1. Global Legal Entity Identifier Updatefor ACSDA General AssemblyApril 4, 2014 Data Services William Hodash Managing Director, DTCC Controlled – Non-Confidential

2. LEI Key Public Policy Objective Strengthen systemic risk capabilities of regulators to analyze positions and transactions of firms they oversee on a globally integrated basis

3. New Acronyms (like any good project) • GLEIS: Global LEI System • ROC: Regulatory Oversight Committee • COU: Central Operating Unit • Pre-LOUs: Pre-Local Operating Units • Pre-LEIs: pre legal entity identifiers • ISO 17442: The Standard • GMEI Utility: Global Markets Entity Identifier Utility (DTCC/SWIFT Collaboration) 3

4. LEI Must Be Standardized Globally The LEI is a single unique 20-character alphanumeric code that is assigned to all entities that are counterparties to financial transactions and listed in an open database, available to all as a public good. The FSB and ROC have endorsed and adopted ISO Standard 17442. • Legal Name – Eastspring Investments (Singapore) Limited • Address – 10 Marina Boulevard, #32-01, Singapore, 018983 • Country of formation – Singapore • Business Registry name and number - Accounting and Corporate Regulatory Authority (ACRA), 199407631H • Entity Status – Active • Legal Form – Limited • Dates of first assignment, last update – 2014-01-24, 2014-02-07 • Date and reason for expiry – N/A 549300T0KLGA41EVVR68 4

5. Industry LEI Initiative Evolution • Driven by need for systemic risk analysis • Office of Financial Research (OFR) formed • Given a specific request from the U.S. Office of Financial Research (OFR) for an industry driven consensus on legal entity identification: • The financial services industry, working through GFMA, formed the Global Trade Association group to formulate a proposal • Objective to develop a global, consensus-based solution for the accurate and unambiguous identification of legal entities engaged in financial transactions  • The Financial Stability Board (FSB) involvement to drive global adoption • The International Organization for Standardization approved ISO 17442 in May 2012 • CFTC Requirements for CICI issued Spring 2012 and require all market participants to have CICIs by April 10, 2013 • Utility Formed in response to industry requirements and use mandated by CFTC– Data collection, maintenance, LEI assignment, QA • The Depository Trust & Clearing Corporation (DTCC) • Society for Worldwide Interbank Financial Telecommunications (SWIFT) • Federated Registration – ANNA • GMEIutility.org

6. Key Industry Requirement: Data Quality Challenges of Maintaining Data Quality • Maintaining singularity (i.e., no duplication) • Ensuring initial and on-going accuracy • Self-registration and on-going maintenance is neither mandated nor does it ensure accuracy • Official jurisdictional Entity Registries tend to be non-public, incomplete, and periodically updated • Applying corporate actions in a consistent manner across jurisdictions is difficult • Thus, validation is essential

7. Global Regulatory Community LEI Initiative  FSB delivered initial recommendations to G20 in June 2012.  FSB transitioned its responsibilities to the Regulatory Oversight Committee (ROC) in January 2013. The ROC adopted the FSB principles. • In March 2013, ROC set out criteria for issuance of the pre-LEI identifiers that could provide an interim solution for the establishment of the Global LEI System consistent with FSB LEI principles. • In July 2013, The ROC published a framework for global endorsement of pre-Local Operating Units • In October 2013, the ROC announced its first three globally endorsed pre-LOUs, including DTCC’s CICI Utility. There are now ten endorsed pre-LOUs. • In October 2013, ESMA stated that reporting to TRs (beginning in Feb 2014) must include pre-LEIs - - October 2013 • ROC is currently working on a common file format for all pre-LOUs

8. Key Current Issues in the GLEIS • Portability • Principles and Practice • Common File Layout • Standardization will facilitate consumption and consolidated file • Global Endorsement • Critical prior to issuance of pre-LEIs • Asset Class Expansion • Moving beyond OTC Derivatives • Data Quality/Maintenance • Requiring entities to maintain • Establishing the GLEIS Foundation/Central Operating Unit • Necessary step for pre-LEIs to become LEIs

9. GMEI Utility • The endorsement of the CICI Utility by the Regulatory Oversight Committee (ROC) allows DTCC/SWIFT to offer the legal entity identifier service globally • We have now adopted the name Global Markets Entity Identifier (GMEI) utility to reflect the global acceptance of the utility’s pre-LEIs across multiple jurisdictions, and to reflect the broad asset class coverage. • New Name, Same Portal: • The identifiers of all endorsed pre-LOUs are referred to generically as pre-LEIs and when the GLEIS is fully operational they will be called LEIs. They are accepted by all 55+ regulators who endorsed the ROC charter, including the CFTC and ESMA.

10. GMEI Utility Operational Principles • Global • Can support reporting across all jurisdictions and asset classes • Can easily support federation of registration, data maintenance, validation • Extensive global industry input to shape solution • Public good • Cost recovery model • Free and unrestricted access • Control • Built to deliver ISO 17442 standard • High quality data is a key focus • Utility strength infrastructure • Expertise • Over ten years of data validation expertise through Avox • Database already houses over 110,000 ISO-compliant, globally accepted pre-LEIs

11. GMEI Utility Functionality  Registration  Self-registration  Assisted registration  Web and Bulk file registration  Number Assignment  SWIFT assignment of ISO 17442 standard  “5493” prefix since November, 2012  Validation  All registrations validated against publicly available sources  Result of validation published  Publication  Free full and delta files published daily  Free internet search  Ongoing Data Quality/Maintenance  Public challenge process  Annual re-certification

12. Global Registrations & Market Share by Pre-LOU

13. Top 10 Countries by Pre-LEI Registrations

14. Potential Partnership Models • DTCC and SWIFT are open to partnering with CSDs and NNAs. Potential to share: • Expertise • Technology • Operating Platform • Revenue • Two types of models: • Facilitator of pre-LEIs issued by GMEI Pre-LOU/Register customer with their express permission • Form own pre-LOU sponsored by local regulator/outsource some key operations to GMEI utility • Current Examples: • CUSIP Global Services • NordLEI • More coming soon