GMEI Utility Common Data Format 2.0 and Level 2 Data FAQ

GMEI Utility
Common Data Format 2.0 and Level 2 Data
Frequently Asked Questions
April 03, 2017
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
TABLE OF CONTENTS
Terminology Updates to Align with Common Data Format 2.0
Why is the GMEI Utility making these changes?
What terms have changed names?
What terms are new for CDF 2.0?
Entity Category
Entity Expiration Reason
Validation Authority ID
Validation Authority Entity ID
Field and Enumeration Changes
Record State / Validation Sources
Registration Status
Level 2 Data
Updates to Portal Registration and Renewal
Updates to Portal Registration and Renewal
Updates to Bulk Service for Registration and Renewal
Associated Reference Documents
Level 2 Data: Who Owns Whom
LEI ROC Policy on Level 2 Data
LEI Common Data File Format 2.0 (LEI-CDF 2.0)
LEI-CDF 2.0 - State Transition Rules
GLEIF Registration Authorities List
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
Terminology Updates to Align with Common Data
Format 2.0
The GMEI Utility is aligning terminology in use on the Portal with language in the
Common Data Format 2.0 (CDF 2.0), as specified by the GLEIF.
Why is the GMEI Utility making these changes?
The GMEI Utility, as one of the first LEI-issuing organizations, has continuously evolved
as standards for LEI issuance have progressed. Because there was existing legacy
terminology that predated the CDF 2.0 specification, these updates align the GMEI Utility
with the published standard.
What terms have changed names?
Table 1 lists the fields whose names have changed. There have been no changes to
these fields' functionality. The Bulk Services Templates reference these updated names,
which are also visible on the GMEI Utility Portal.
Table 1 Updated CDF Term Names
Previous Name
Updated Name for CDF 2.0
Anglicized Legal Name
ASCII Transliterated Legal Name
Registered Address
Legal Address (multiple fields)
State
Region
Business Registry
Registration Authority ID
Business Registry Number Registration Authority Entity ID
What terms are new for CDF 2.0?
This section outlines the terms that have been introduced in the Common Data Format
version 2.0.
Entity Category
Indicates (where applicable) the category of entity identified by this LEI data record, as a
more specific category within the broad definition given in ISO 17442.
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BANK: The legal entity is a bank.
BRANCH: The legal entity is a branch of another legal entity.
Note
Branch records must define a Headquarters Relationship. For additional guidance,
see Level 2 Data on page 7.
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CORPORATION: The legal entity is a corporate entity.
FUND: The legal entity is a fund managed by another legal entity.
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
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GOVERNMENT: The legal entity is a government entity, department, ministry, or
municipal.
SOLE_PROPRIETOR: The legal entity is an individual acting in a business capacity.
OTHER: All other legal entities not covered by an existing category.
Entity Expiration Reason
The Entity Expiration Reason is necessary if the entity is being registered or updated to a
status of INACTIVE. The valid Entity Expiration Reasons include DISSOLVED,
CORPORATE_ACTION, and OTHER.
Table 2 Entity Expiration Reason Updates
Expiry Reason (OLD)
Expiration Reason (NEW)
CEASED
DISSOLVED
MERGED
CORPORATE_ACTION
OTHER
Validation Authority ID
The (primary) registration authority used by the LOU to validate the entity data. The
reference code of the registration authority; taken from the Registration Authorities Code
List (RACL) that the GLEIF maintains at https://www.gleif.org/en/about-lei/gleifregistration-authorities-list/.
Validation Authority Entity ID
The identifier of the entity at the indicated registration authority. It is typically the identifier
of the legal entity as maintained by a business registry in the jurisdiction of legal
registration. If the entity is one that is not recorded in a business registry (for example,
one of the varieties of funds registered instead with financial regulators), it is the identifier
of the entity in the appropriate registration authority.
Field and Enumeration Changes
Record State / Validation Sources
Record State is now termed Validation Sources.
Table 3 lists the previous and current enumerated values for Validation Sources:
Table 3 Field and Enumeration Changes
Record State (OLD)
Validation Sources (NEW)
PUBLIC_SOURCES
FULLY_CORROBORATED
MULTIPLE_SOURCES
PARTIALLY_CORROBORATED
REGISTRANT_SOURCE ENTITY_SUPPLIED_ONLY
UNDER_REVIEW
PENDING
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
Registration Status
The Registration Status field now has additional values that provide more granular
detail on the status of the LEI record.
Table 4 Registration Status
Renewal State (OLD) Registration Status (NEW)
CURRENT
ISSUED
NOT_CURRENT
LAPSED
PENDING_VALIDATION
DUPLICATE
MERGED
RETIRED
ANNULLED
CANCELLED
TRANSFERRED
PENDING_TRANSFER
PENDING_ARCHIVAL
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
Level 2 Data
The information available with LEI reference data to date is referred to as ‘Level 1’ data.
It provides the answer to the question of ‘who is who’. In a next step, LEI data will be
enhanced to include ‘Level 2’ data that will answer the question of ‘who owns whom’,
allowing the identification of the direct and ultimate parents of a legal entity.
The collection, validation and publication of parent information will commence on 1 May
2017. Entities that want to register or renew an LEI will report the ‘ultimate accounting
consolidating parent’, defined as the highest level legal entity by preparing consolidated
financial statements, as well as their ‘direct accounting consolidating parent’.
To implement Level 2 Data functionality on the GMEI Utility, new fields will be provided in
order to enable input of this data on the Portal during the Registration and Renewal. In
addition, the Bulk Service Templates for Registration and Renewal will be updated with
additional columns to hold this data.
Updates to Portal Registration and Renewal
The GMEI Utility Portal previously accepted up to ten distinct Ultimate Parent
relationships on the Relationship Information page. These optional reporting
relationships were based on percentage ownership.
With Level 2 data, reporting of Direct and Ultimate Parent relationships is now
mandatory, and is based on the accounting relationship— the direct and ultimate
consolidating parent—rather than on the percentage ownership.
The GMEI Utility Portal will provide forms during LEI Registration and Renewal to:
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Search for and input the entity’s Direct and Ultimate Consolidating Parents
Provide information on a parent entity that does not have an LEI
Provide Opt-Out Reasons for reporting these relationships when necessary
Searching for and selecting a Direct or Ultimate Parent will be similar to the search and
select feature currently available on the GMEI Utility Portal for reporting these
relationships.
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
Updates to Portal Registration and Renewal
Figure 1 illustrates the Relationship Information page of the Registration process.
Figure 1 Relationship Information Page
If either of the entity’s parents is missing an LEI assignment, provision will be made to
enter the parent entity’s legal name, address, and business registry information as
needed.
In certain instances, an entity may not be able to report the parental relationship, in which
case it may be necessary to “Opt-Out” of one or both relationships. The reasons an entity
may opt-out of relationship reporting include:
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No LEI: this is a default Opt-Out reason that will be referenced when the relationship
is not yet known (for example, data currently defined on the GMEI Utility Portal before
any relationships have been provided).
Natural Persons: the entity is controlled by natural person(s) without any
intermediate legal entity meeting the definition of parent.
Non Consolidating: the entity is controlled by legal entities not subject to preparing
consolidated financial statements.
No Known Person: there is no known person(s) controlling the entity (for example,
diversified shareholding).
Legal Obstacles: legal obstacles in the laws or regulations of a jurisdiction prevent
providing or publishing this information.
Consent Not Obtained: permission was not granted by the parent entity to provide
or publish this information.
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
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Binding Legal Commitments: contractual commitments prevent providing or
publishing this information.
Disclosure Detrimental: disclosure of this information would be detrimental to the
legal entity or the relevant parent.
Updates to Bulk Service for Registration and Renewal
All of the above provisions regarding Portal updates in support of Level 2 Data will
also apply to the Bulk Service.
l The Registration and Renewal Templates will provide the appropriate columns to
define the necessary parental relationships or opt-out reasons.
l The Bulk Reference Data spreadsheet will be updated to provide support for Level 2
Data.
The following rules apply when completing the relationship data in the templates:
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Report the Ultimate Parent and Direct Parent LEIs in the columns provided, if
available.
l Provide the Opt-Out reason for either or both relationships as necessary (see the list
of Opt-Out Reasons provided in Bulk Reference Data spreadsheet)
l If the Ultimate and/or Direct Parent has no registered LEI, and there is no Opt-Out
reason provided, provide the Legal Name, Address, and Registration Authority
(Business Registry) information for the parent in the fields supplied.
Table 5 lists the new fields provided for Level 2 Data, along with a brief description.
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Table 5 New Level 2 Data Fields
New Field Name
Field Description
UltimateParentLEI
The LEI of the entity’s ultimate accounting
consolidating parent.
UltimateParentOptOut
The Opt-Out Reason for not providing the
Ultimate Parent Relationship. The Bulk
Reference Data spreadsheet lists permissible
values.
DirectParentLEI
The LEI of the entity’s direct accounting
consolidating parent.
DirectParentOptOut
The Opt-Out Reason for not providing the Direct
Parent relationship. The Bulk Reference Data
spreadsheet lists permissible values.
NoLEIUltimateParentLegalName
Ultimate Parent exists but has no registered LEI.
Provide the Legal Name of the Ultimate Parent.
NoLEIUltimateParentAddressLineOne
Ultimate Parent exists but has no registered LEI.
Provide the Address of the Ultimate Parent.
NoLEIUltimateParentCountry
Ultimate Parent exists but has no registered LEI.
Provide the Country of the Ultimate Parent.
NoLEIUltimateParentRegion
Ultimate Parent exists but has no registered LEI.
Provide the Region of the Ultimate Parent.
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
Table 5 New Level 2 Data Fields (continued)
New Field Name
Field Description
NoLEIUltimateParentCity
Ultimate Parent exists but has no registered LEI.
Provide the City of the Ultimate Parent.
NoLEIUltimateParentRegistrationAuthorityID
Ultimate Parent exists but has no registered LEI.
Provide the Registration Authority ID of the
Ultimate Parent. See the Bulk Reference Data
spreadsheet for permissible values.
NoLEIUltimateParentRegistrationAuthorityEntityID Ultimate Parent exists but has no registered LEI.
Provide the Registration Authority Entity ID of the
Ultimate Parent. If Registration Authority ID is
“Not Available” leave blank.
NoLEIDirectParentLegalName
Direct Parent exists, but has no registered LEI.
Provide the Legal Name of the Direct Parent.
NoLEIDirectParentAddressLineOne
Direct Parent exists but has no registered LEI.
Provide the Address of the Direct Parent.
NoLEIDirectParentCountry
Direct Parent exists but has no registered LEI.
Provide the Country of the Direct Parent.
NoLEIDirectParentRegion
Direct Parent exists but has no registered LEI.
Provide the Region of the Direct Parent.
NoLEIDirectParentCity
Direct Parent exists but has no registered LEI.
Provide the City of the Direct Parent.
NoLEIDirectParentRegistrationAuthorityID
Direct Parent exists but has no registered LEI.
Provide the Registration Authority ID of the
Direct Parent. See the Bulk Reference Data
spreadsheet for permissible values.
NoLEIDirectParentRegistrationAuthorityEntityID
Direct Parent exists but has no registered LEI.
Provide the Registration Authority Entity ID of the
Direct Parent. If Registration Authority ID is “Not
Available” leave blank.
HeadquartersLEI
LEI of the Headquarters, provided only if the
entity is an international Branch. In this case,
none of the other Level 2 fields in this table
apply.
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GMEI Utility Common Data Format 2.0 and Level 2 Data - Frequently Asked Questions
Associated Reference Documents
Level 2 Data: Who Owns Whom
https://www.gleif.org/en/lei-data/access-and-use-lei-data/level-2-data-who-ownswhom/lei-roc-policy-on-level-2-data
LEI ROC Policy on Level 2 Data
http://www.leiroc.org/publications/gls/lou_20161003-1.pdf
LEI Common Data File Format 2.0 (LEI-CDF 2.0)
https://www.gleif.org/content/2-about-lei/5-common-data-file-format/1-lei-cdf-format/leicdf-2-0.pdf
LEI-CDF 2.0 - State Transition Rules
https://www.gleif.org/content/2-about-lei/5-common-data-file-format/1-lei-cdf-format/leicdf-2-0-str-vr.pdf
GLEIF Registration Authorities List
https://www.gleif.org/content/2-about-lei/6-gleif-registration-authorities-list/2017-01-11_
registration-authorities-list-final-version-1.1.pdf
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