November 19, 2018

LEIROC published the final policy of Regulatory Oversight Committee (ROC) for incorporating legal entity events and data history in the Global Legal Entity Identifier System (GLEIS). This policy has been informed by a public consultation held between July 26, 2017 and September 29, 2017 and a workshop held with respondents to the public consultation on March 28, 2018. LEIROC also published a report proposing a limited update to the way relationships affecting funds are recorded in the GLEIS. The consultation report contains a questionnaire for respondents and the consultation for this report ends on January 14, 2019.

The following are the key features of the final policy of ROC on incorporating legal events and data history in GLEIS:

  • A change in terminology to refer to the events to be captured in the reference and relationship data in the GLEIS as “legal entity events” rather than corporate actions.
  • An incremental approach to implementation of capturing legal entity events that would prioritize those events that occur relatively frequently and directly affect the Level 1 and Level 2 reference data (for example, name changes, mergers, and acquisitions) and place a lower implementation priority on those events that occur relatively infrequently.
  • Commercial or regulatory data feeds should be incorporated into the GLEIS to notify Local Operating Units of potential changes to entities under their maintenance .
  • Effective dates (reflecting when legal entity events become legally effective) should be incorporated into the GLEIS.
  • Users should be able to easily access and use an entity’s data history through multiple channels.
  • Complex acquisitions will reflect as accurately as possible the chain of legal events as reflected in the official registries of the relevant jurisdictions.
  • Spin-off relationships will be recorded in the GLEIS on a fully optional basis, with possible mandatory reporting at a future date to be determined by the ROC.

The consultation on the way relationships affecting funds  are recorded in GLEIS is aimed to ensure that the implementation of relationship data is consistent throughout the GLEIS and to provide a means to facilitate a standardized collection of fund relationship information at the global level. These objectives are being pursued by providing a definition for each fund relationship and better aligning the data structure with what is done for direct and ultimate accounting parent entities. The report proposes to replace the current optional reporting of a single “fund family” relationship as part of Level 1 (reference data of the entity) with the following relationships, as part of “Level 2” data (relationship data): Fund Management Entity relationship, Umbrella Structures relationship, and Master-Feeder relationship. Responses to the questionnaire in Annex 4 will inform the final version of the policy framework that the ROC will approve for implementation by the Global Legal Entity Identifier Foundation (GLEIF). Implementation would not take place before January 2020.

 

Comment Due Date: January 14, 2019

Keywords: International, Banking, Insurance, Securities, LEI, LOU, GLEIS, GLEIF, LEIROC

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