Legal Entity Identifier (LEI)

Prior to the implementation of Level 2 Data effective 1st May 2017 The information assigned to the Legal Entity Identifier (LEI) e.g. the official name of a legal entity and its registered address etc., is referred to as ‘Level 1’ data. It provides the answer to the question of ‘who is who’. With the release of Level 2 the LEI data pool will be enhanced to include the answer to the question of ‘who owns whom’. This data will allow the identification of the direct and ultimate parents of a legal entity and, vice versa, in order that the entities owned by individual companies can be researched.

The collection of LEI Level 2 Data is a requirement set by the LEI ROC (LEI Regulatory Oversight Committee) and the GLEIF (Global LEI Foundation). For more information please see the LEI ROC publication.

Yes, this is a mandatory requirement set the LEI ROC (LEI Regulatory Oversight Committee) and the GLEIF (Global LEI Foundation).

As quoted by the GLEIF: “The collection, validation and publication of parent information will commence on 1 May 2017.” This means that from 1st May 2017 all new LEI requests and all LEI renewal requests submitted required LEI Level 2 Data to be provided. If you currently maintain LEIs with us, we encourage you to provide us with this information as soon as possible, so that we can update your LEI record ahead of its Annual Renewal.

Please email LEI@lseg.com and request for bulk or individual level 2 update templates.

In order for us to validate the relationship between your LEI and its direct and ultimate parent, we request you to provide us with the validation document that confirms the existence of the Parent relationship such as the accounts fling, regulatory filing or other publicly available source that we can use to confirm the relationship.

If your LEI does not have a direct or ultimate parent, in the Parent Name field you will need to choose ‘N/A’ from the drop down and then select one of the following from the Exception Reason field:

• NATURAL_PERSONS
  The parent entity is a natural person; There is no parent according to the definition used, because the entity is controlled by natural person(s) without any intermediate legal entity meeting the definition of accounting consolidating parent.
• NO_KNOWN_PERSON
  There is no parent according to the definition used, because there is no known person controlling the entity (e.g. diversified shareholding).
• NON_CONSOLIDATING
  There is no parent according to the definition used, because the entity is controlled by legal entities not subject to preparing consolidated financial statements.

If you cannot disclose your LEIs direct or ultimate parent, in the Parent Name field you will need to choose ‘N/A’ from the drop down and then select one of the following from the Exception Reason field:

• BINDING_LEGAL_COMMITMENTS
• CONSENT_NOT_OBTAINED
• DETRIMENT_NOT_EXCLUDED
• DISCLOSURE_DETRIMENTAL
• LEGAL_OBSTACLES
   

You will need to renew your LEI and you can add the Level 2 data upon renewal by clicking the ‘edit record’ box once you have clicked ‘Select for Renewal’

The LEI ROC retained the following definition: The “direct accounting consolidating parent” of legal entity X would be defined as the lowest level legal entity that prepares consolidated financial statements that consolidate entity X, based on the accounting definition of consolidation applying to this parent.

The LEI ROC retains the definition of ultimate parent envisaged in the public consultation: the “ultimate accounting consolidating parent” of entity X would be the highest level legal entity preparing consolidated financial statements that consolidate entity X, based on the accounting definition of consolidation applying to this parent.

For assistance in which fields you will need to fill in please see the LEI Level 2 Data Help Sheet here

Please see the GLEIF link below for more information on Level 2 Data here

Please see the link below for an overview on the LEI ROC Policy on Level 2 Data:

• On LEI ROCs website
• On GLEIFs website

Yes please see the ‘LEI Level 2 Terminology Explained’ guide.

If the LEI has direct and ultimate parent companies, you would only report the parent information if the direct and ultimate parent are based on accounting consolidating standards. i.e. the entity’s accounts consolidate into the parents. If a Parent entity exists but cannot be disclosed, please choose the appropriate exception reason (see exception reason definitions from the ‘LEI Level 2 Terminology Explained’ guide.

The GLEIF and LEI ROC are working on developing the fund policy for reporting Level 2/Parent information. If the fund consolidates as per accounting consolidating standards then you would report the parent entities the fund’s accounts consolidate into.

GLEIF have confirmed that in the case there is doubt on how the direct and ultimate parent information should be reported for funds, a reporting exception of NON_CONSOLIDATING or NO_KNOWN_PERSON is acceptable.

If the Fund does not consolidate it’s accounts into the parents, a reporting exception of NON_CONSOLIDATING is acceptable.