The recommendations provide high-level guidance concerning membership on the Regulatory Oversight Committee (ROC). Regulatory authorities should indicate interest in serving as members, as well as their support for the LEI high-level principles and charter for the ROC. The LEI Implementation Group will develop the ROC charter, covering the details of member appointment.

Membership in the Central Operating Unit (COU) and Local Operating Units (LOU) will be determined after the charter for the ROC has been drafted and adopted. However, the FSB’s recommendations call for the ROC to appoint the initial Board of Directors of the COU and engage industry participants in establishing the COU. The FSB’s recommendations also recognize the value of contributions from members inside and outside the financial industry, including industries, such as retail and health care, that have successfully addressed complex challenges in creating global identification systems. Their inclusion is viewed as strengthening the global LEI system. Finally, the FSB’s recommendations provide leeway for the scope of the LOU. There can be a single LOU or multiple LOUs per jurisdiction; the LOUs can be public or private, country-specific or regional. For example, in the U.S., the supplier of the CFTC Interim Compliant Identifier (CICI) is the first candidate to become an LOU.

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