The Clearing House Association, along with seven other trade associations, submitted a comment letter to the Office of Financial Research on a proposal to develop a system of uniform legal-entity identifiers (LEIs) to measure and evaluate systemic risk in the financial system. The comment letter urges OFR (i) to work with all the major domestic and global financial-services regulators toward one LEI standard, (ii) to choose a non-profit LEI issuer with a stable funding source and an open and transparent process, (iii) to define clearly which parties are responsible for obtaining LEIs, (iv) to institute an LEI system in accordance with the interagency whitepaper, “Creating a Linchpin for Financial Data: The Need for a Legal Entity Identifier,” especially one that issues neutral LEIs, and (v) to consider carefully the phase-in strategy and which data elements to require. The associations noted that they are working together to develop an industry proposal.