The mandatory case
In the United States, entities that report under CFTC Part 45 swap data rules and SEC Regulation SBSR — and, from October 2026, private fund advisers filing SEC Form PF — must hold a valid LEI. For them the question is not whether, but when.
The voluntary case
Beyond any mandate, an LEI is a globally-recognised, independently-verifiable identity. It speeds American bank onboarding and KYC, satisfies overseas counterparties, and signals transparency — value that exists with or without a rule.
Who should consider one
US banks, swap dealers and major swap participants, broker-dealers, registered investment advisers, and insurers — and any American exporter, group or SPV that faces banks or counterparties abroad.
The bottom line
A mandate tells you that you must have an LEI; the business case tells you why you would want one anyway.
Key takeaways
• Mandatory for entities under the applicable reporting regime.
• Voluntarily valuable as a global trust signal.
• Speeds bank onboarding and cross-border dealing.
• One LEI works in every market.
