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New LEI registration service for SSAS and Family Pension Trust

The Markets in Financial Instruments Directive (MiFID) is the EU legislation that regulates firms which provide services to clients linked to financial instruments, such as shares, bonds, units in collective investment schemes and derivatives and how they are traded.

A change to this legislation, which takes effect from 3 January 2018, affects all independently registered member-directed pension schemes like small self-administered schemes (SSASs) and Family Pension Trusts. From this date, if a scheme holds, or its trustees wish to establish, one or more stockbroking accounts or investment portfolios, including discretionary and execution-only arrangements, it will be required to obtain a Legal Entity Identifier (LEI) before trades can take place.

The LEI was introduced globally in response to the financial crisis.  It is a twenty character, alpha-numeric code, which will enable immediate and accurate identification of a party to a financial transaction and help to limit market abuse and financial fraud.  SSASs and Family Pension Trusts require an LEI as they are classed as being a legal entity trading in reportable financial instruments. Self-invested personal pensions are not affected by this change.

The London Stock Exchange is the only authorised LEI issuing organisation in the UK.  Currently, the fee for initial registration is £115 plus VAT.  Once an LEI has been obtained, it must be renewed on an annual basis if trades in reportable financial instruments are required in the future.  The current annual renewal fee is £70 plus VAT.

It is the responsibility of the trustees of the pension scheme, to obtain an LEI if requested by an investment firm.  Some investment firms are already requesting an LEI for schemes establishing new investment portfolios, to ensure they comply with the requirements in advance of 3 January 2018.

Certain investment firms will offer an LEI registration and renewal service.

Should an investment firm not offer this service, Rowanmoor will arrange to apply for an LEI on the scheme’s behalf and manage renewals for the scheme at the cost price of the London Stock Exchange service and will not charge any additional fees for this service.

Should the investment firm decline to offer a renewal service in future, Rowanmoor can arrange renewal of the existing LEI for the scheme.

Only one LEI is required per scheme regardless of how many stockbroker accounts or investment portfolios are held as assets of the scheme.  Many schemes will hold more than one investment account or stockbroker portfolio with different investment firms; only one firm should be instructed to obtain and renew the LEI for the scheme to avoid potential duplication.  The organisation, which took responsibility for registering the LEI for the scheme is also responsible for renewal and should automatically deal with this on behalf of the trustees.

For further information, please contact us or send your questions via our enquiry box on the right hand side.

 

 

 

 

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