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Can a DAR be one of the LARs? #2

Closed nkongsuwan closed 10 months ago

nkongsuwan commented 10 months ago

Legal Entity vLEI Credential

Section Name

6.3.1.f

Row number

62

Question/Comment

In row 62, The DAR SHOULD designate at least three (3) LARs .... I suggest clarifying if the DAR can or cannot him/herself be one of the LARs.

nkongsuwan commented 10 months ago

I would like to also suggest that the EGF clarifies if a DAR of a QVI can also be one of its QARs.

kmckenna-gleif commented 10 months ago

Thank you Nuttawut. Yes, a DAR of a legal entity can decide to become a LAR even in the scenario in which there are enough other authorized signatories or employees to fulfil the role of a LAR. Of course, in the sole authorized signatory/employee case for a legal entity, the DAR also would be the LAR and the OOR Person.

kmckenna-gleif commented 10 months ago

And to your additional comment, yes a DAR of a QVI also can decide to become a QAR. Notes can be added in the Frameworks to clarify this for both DAR/LAR and DAR/QAR.