Your bank may obtain an LEI by applying online with an acceptable LEI issuer. While we cannot recommend any particular utility for obtaining an LEI, two examples of acceptable LEI issuers are the Global Market Entity Identifier Utility, or GMEI Utility, and Bloomberg.

While we understand that your bank is not subject to HMDA reporting requirements, the HMDA rules set the standards for LEI issuers, which must be endorsed by the LEI Regulatory Oversight Committee or Global LEI Foundation. GMEI Utility and Bloomberg are accredited by the Global LEI Foundation and consequently are acceptable LEI issuers. Several other acceptable issuers are listed at https://www.gleif.org/en/about-lei/how-to-get-an-lei-find-lei-issuing-organizations.

Also, we note that there is a cost to applying for an LEI and maintaining the LEI registration. Your bank may wish to contact the software vendor to see if there is a possible workaround, given that your bank is not otherwise required to obtain an LEI.

For resources related to our guidance, please see:

• Regulation C, 12 CFR 1003.5(a)(3)(vii) (“A financial institution shall provide with its submission: . . . (vii) Its Legal Entity Identifier (LEI) as described in § 1003.4(a)(1)(i)(A).”)

• Regulation C, 12 CFR 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

• CFPB, HMDA Final Rule, 80 Fed. Reg. 66127, 66247 (October 28, 2015) (“Despite the cost, the Bureau believes that the benefit of all HMDA reporters using an LEI may justify the associated costs. An LEI could improve the ability to identify financial institution reporting the data and link it to its corporate family. Facilitating identification of a financial institution’s corporate family could help data users identify possible discriminatory lending patterns and assist in identifying market activity and risks by related companies.”)

• CFPB, HMDA Final Rule, 80 Fed. Reg. 66127, 66247 (October 28, 2015) (“All of the suggested alternatives above would still result in a lack of information to enable users to link corporate information to the financial institution reporting HMDA data. Accordingly, the Bureau is adopting § 1003.5(a)(3) to require an institution to provide its LEI with its submission.”)