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Under the new HMDA rules, we are required to obtain a legal entity identifier number (LEI). I saw a webinar in which Fannie Mae and Freddie Mac recommend obtaining an LEI from the Global Market Entity Identifier (GMEI) Utility. Does the IBA recommend any particular utility (or other entity) for obtaining an LEI? – IBA Compliance Connection

IBA Compliance Connection

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Under the new HMDA rules, we are required to obtain a legal entity identifier number (LEI). I saw a webinar in which Fannie Mae and Freddie Mac recommend obtaining an LEI from the Global Market Entity Identifier (GMEI) Utility. Does the IBA recommend any particular utility (or other entity) for obtaining an LEI?

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While we do not recommend any particular utility for obtaining an LEI (which is a necessary component of the required Universal Loan Identifier), the GMEI Utility certainly is an acceptable LEI issuer for HMDA filing purposes.

Before the LEI requirement in the HMDA final rule takes effect on January 1, 2018, HMDA reporters must obtain an LEI issued by a utility endorsed by the LEI Regulatory Oversight Committee or a utility endorsed or otherwise governed by the Global LEI Foundation. GMEI Utility is accredited by the Global LEI Foundation and consequently is an acceptable LEI issuer. Other acceptable issuers are listed at https://www.gleif.org/en/about-lei/how-to-get-an-lei-find-lei-issuing-organizations.

For resources related to our guidance, please see:

  • HMDA Final Rule, 80 Fed. Reg. 66127, 66312–66313 (October 28, 2015) (“A financial institution shall provide with its submission: . . . (vii) Its Legal Entity Identifier (LEI) as described in § 1003.4(a)(1)(i)(A).”)

  • HMDA Final Rule, 80 Fed. Reg. 66127, 66310 (October 28, 2015) (As described in § 1003.4(a)(1)(i)(A), LEIs must be “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.”)

  • How to Get an LEI: Find LEI Issuing Organizations

  • GMEI Utility Website