On Oct. 12, 2026, DTC notified Participants that they must provide a valid LEI by Dec. 12, 2026; requirement does not apply to DTC Limited Participants or CDS Participants.
Provide that Participants who do not have a LEI on file shall have 60 calendar days from Important Notice to submit their LEIs.
Failure to provide a valid LEI within 60 calendar days from Important Notice could subject the Participant to disciplinary sanctions, including a fine.
On Apr. 25, DTC proposed amendment requiring legal entity identifiers
DTC, FICC and NSCC proposed amendments on legal entity identifier requirements.
The LEI requirement would improve quality of data that is collected from participants, expedite KYC and due diligence, enhance risk management, reduce record duplication.
Concurrently, NSCC published notice of submission of rule filing to amend LEI rules.
DTC Proposed Amendments
Requires each applicant applying to become Participant, Pledgee, DRS Agent or FAST Agent to obtain and provide a legal entity identifier (LEI) to DTC as part of application.
Participant, Pledgee, DRS Agent, FAST Agent to have current LEI on file at all times.
CDS Clearing and Depository Services Inc. to provide DTC with LEI for each current participant for which CDS maintains subaccount and for each newly added participant.
FICC Proposed Amendments
Requires each applicant applying to become MBSD Clearing Member or MBSD Cash Settling Bank Member to obtain and provide a LEI as part of membership application.
Each GSD Funds-Only Settling Bank Member, MBSD Clearing Member and MBSD Cash Settling Bank Member required to have a current LEI on file with FICC at all times.
Also proposing to revise the defined term used in the GSD rules relating to legal entity identifier to conform to the proposed defined term being added to the MBSD Rules.
NSCC Proposed Amendments
Requires each applicant applying to become a Member or a Limited Member to obtain and provide a legal entity identifier to NSCC as part of its membership application.
Each Member and Limited Member to have a current LEI on file with NSCC at all times.
Also each Sponsoring Member to provide NSCC with an LEI for each of their current Sponsored Members and for each newly added Sponsored Member going forward.
CDS Clearing and Depository Services Inc. to provide NSCC with LEI for each current participant for which CDS maintains subaccount and for each newly added participant.
Consultation
Comments on proposed rule changes due 21 days from publication in federal register.
May 2, 2025 SEC FICC Approval
On May 2, 2025, SEC issued notice of filing, immediate effectiveness of proposed rule.
On May 2, 2025, SEC issued notice of filing, immediate effectiveness for DTC, NSCC.
May 8, 2025 SEC Fed Reg Approvals
On May 8, 2025, SEC published DTC, NSCC, and FICC approvals in federal register.
Aug. 2026 DTC LEI Deadline
On Aug. 24, 2026, DTC notified members that they must provide a valid LEI by Oct. 24, 2026; requirement does not apply to NSCC Limited Members or CDS Participants.
Provide that members who do not have a LEI on file with NSCC shall have 60 calendar days from the date members are notified by Important Notice to submit their LEIs.
Failure to provide a valid LEI within 60 calendar days from the date that Members are notified by Important Notice could subject the Member to disciplinary sanctions fine.
Oct. 2026 DTC LEI Requirement Deadline
On Oct. 12, 2026, DTC notified Participants that they must provide a valid LEI by Dec. 12, 2026; requirement does not apply to DTC Limited Participants or CDS Participants.
Provide that Participants who do not have a LEI on file shall have 60 calendar days from Important Notice to submit their LEIs.
Failure to provide a valid LEI within 60 calendar days from Important Notice could subject the Participant to disciplinary sanctions, including a fine.
