514. In order to ensure a timely update of the LEI in case of merger, acquisition and other corporate events, ESMA proposed in the Consultation Paper the definition of specific procedure to be followed by TRs. The process complements the procedures established for counterparties as specified in section 4.4.2.2 of the Consultation Paper.

515. ESMA indicates that the LEI update should occur on the date of the corporate restructuring event.

516. ESMA also notes that if the request to update the LEI is received by the TR later than 30 days prior to that event, the TR should perform it as soon as possible and no later than 30 calendar days from receiving the request.

517. Almost all market participants welcomed the proposal to set up a clear timeframe to update the LEI and most of them support the idea that the LEI update should be executed by TRs on the day of the corporate restructuring event. However, the most criticised aspect for the set-up of a specific timeframe for the LEI update is related to the provision of documentation by counterparties. For this reason, some respondents suggested that any specific timeframe should be based upon the time that proper evidence is supplied to TRs and not the simple notification of a merger.