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Version date: 6 January 2020 - onwards

3.19 Identifying and reporting on beneficiaries

Q40. Are there any other instances that need to be clarified? Please elaborate on the reasons for your response.

324. In the CP, ESMA stated that beneficiaries are always to be reported when they differ from the counterparty to the SFT in accordance with the RTS on reporting.

325. One respondent to the CP noted that allocation of LEIs for beneficiaries should be extended also to ring-fenced pools since they are eligible for an LEI and can constitute a different entity from counterparties as separate segregation of assets.

326. No other issue was raised by respondents. ESMA has updated the Guidelines accordingly.

Comparing proposed amendment...