Many pension schemes will need to obtain a Legal Entity Identifier (LEI) from the London Stock Exchange by 3 January 2018 in order for their investment managers to be able to continue to trade on financial markets in the UK on the scheme’s behalf.
From 3 January 2018, financial institutions and investment managers subject to reporting obligations under the Markets in Financial Instruments Directive (MiFID II) are required to report on all relevant financial transactions, which includes equities and bonds. In order to do so, they will require an LEI for each party to the transaction. An LEI is a unique identifier for legal entities or structures, including trusts.
If a pension scheme is eligible for an LEI and does not have one, the scheme’s investment managers will not be able to continue to provide investment services relating to the execution of relevant financial transactions.
In view of the impending deadline, trustees should be raising the issue with their investment managers as soon as possible to ascertain whether they already have an LEI and, if not, whether they need one.
Pension scheme trustees will ultimately be responsible for obtaining an LEI by the deadline. However, some investment managers may agree to apply for an LEI on the scheme’s behalf.
The London Stock Exchange will charge an initial fee of £115 plus VAT and an annual maintenance fee of £70 plus VAT.