GMEI UTILITY COMMON DATA FORMAT 2.0 AND LEVEL 2 DATA FREQUENTLY ASKED QUESTIONS SEPTEMBER 14, 2017

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1 GMEI UTILITY COMMON DATA FORMAT 2.0 AND LEVEL 2 DATA FREQUENTLY ASKED QUESTIONS SEPTEMBER 14, 2017

2 @ 2017, The Depository Trust & Clearing Corporation and/or its affiliates. All rights reserved. Publication Code: GM107 Service: GMEI Utility Title: Common Data Format 2.0 and Level 2 Data Frequently Asked Questions

3 TABLE OF CONTENTS CHAPTER 1: TERMINOLOGY UPDATES TO ALIGN WITH COMMON DATA FORMAT Why is the GMEI Utility Making These Changes? 4 What Terms Have Changed Names? 4 What Terms are New for CDF 2.0? 4 Entity Category 4 Entity Expiration Reason 5 Validation Authority ID 5 Validation Authority Entity ID 5 Field and Enumeration Changes 5 Record State / Validation Sources 5 Registration Status 6 CHAPTER 2: LEVEL 2 DATA 7 Updates to Portal Registration and Renewal 7 Updates to Portal Registration and Renewal 8 Updates to Bulk Service for Registration and Renewal 9 APPENDIX A: ASSOCIATED REFERENCE DOCUMENTS 11 Level 2 Data: Who Owns Whom 11 LEI ROC Policy on Level 2 Data 11 LEI Common Data File Format 2.0 (LEI-CDF 2.0) 11 LEI-CDF State Transition Rules 11 GLEIF Registration Authorities List 11

4 CHAPTER 1: 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 1.1 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 1.1 Updated CDF Term Names Previous Name Updated Name for CDF 2.0 Anglicized Legal Name Registered Address State Business Registry ASCII Transliterated Legal Name Legal Address (multiple fields) Region 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 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. CORPORATION: The legal entity is a corporate entity. FUND: The legal entity is a fund managed by another legal entity. GOVERNMENT: The legal entity government entity, department, ministry, or municipal. Terminology Updates to Align with Common Data Format 2.0 4

5 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 1.2 Entity Expiration Reason Updates Expiry Reason (OLD) CEASED MERGED Expiration Reason (NEW) DISSOLVED 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 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 1.3 lists the previous and current enumerated values for Validation Sources: Table 1.3 Field and Enumeration Changes Record State (OLD) PUBLIC_SOURCES MULTIPLE_SOURCES Validation Sources (NEW) FULLY_CORROBORATED PARTIALLY_CORROBORATED REGISTRANT_SOURCE ENTITY_SUPPLIED_ONLY UNDER_REVIEW PENDING Terminology Updates to Align with Common Data Format 2.0 5

6 Registration Status The Registration Status field now has additional values that provide more granular detail on the status of the LEI record. Table 1.4 Registration Status Renewal State (OLD) Registration Status (NEW) CURRENT NOT_CURRENT ISSUED LAPSED PENDING_VALIDATION DUPLICATE MERGED RETIRED ANNULLED CANCELLED TRANSFERRED PENDING_TRANSFER PENDING_ARCHIVAL Terminology Updates to Align with Common Data Format 2.0 6

7 CHAPTER 2: 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 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: 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. Level 2 Data 7

8 Updates to Portal Registration and Renewal Figure 2.1 illustrates the Relationship Information page of the Registration process. Figure 2.1 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: No LEI: the legal entity is aware of their parent entity, but the parent does not have an LEI, or does not consent to have an LEI. 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. 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. Level 2 Data 8

9 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. The Registration and Renewal Templates will provide the appropriate columns to define the necessary parental relationships or opt-out reasons. 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: Report the Ultimate Parent and Direct Parent LEIs in the columns provided, if available. 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) 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 2.1 lists the new fields provided for Level 2 Data, along with a brief description. Table 2.1 New Level 2 Data Fields New Field Name UltimateParentLEI UltimateParentOptOut DirectParentLEI DirectParentOptOut NoLEIUltimateParentLegalName NoLEIUltimateParentAddressLineOne NoLEIUltimateParentCountry NoLEIUltimateParentRegion NoLEIUltimateParentCity NoLEIUltimateParentRegistrationAuthorityID Field Description The LEI of the entity s ultimate accounting consolidating parent. The Opt-Out Reason for not providing the Ultimate Parent Relationship. The Bulk Reference Data spreadsheet lists permissible values. The LEI of the entity s direct accounting consolidating parent. The Opt-Out Reason for not providing the Direct Parent relationship. The Bulk Reference Data spreadsheet lists permissible values. Provide the Legal Name of the Ultimate Parent. Provide the Address of the Ultimate Parent. Provide the Country of the Ultimate Parent. Provide the Region of the Ultimate Parent. Provide the City of the Ultimate Parent. Provide the Registration Authority ID of the Ultimate Parent. See the Bulk Reference Data spreadsheet for permissible values. Level 2 Data 9

10 Table 2.1 New Level 2 Data Fields (continued) New Field Name NoLEIUltimateParentRegistrationAuthorityEntityID NoLEIDirectParentLegalName NoLEIDirectParentAddressLineOne NoLEIDirectParentCountry NoLEIDirectParentRegion NoLEIDirectParentCity NoLEIDirectParentRegistrationAuthorityID NoLEIDirectParentRegistrationAuthorityEntityID HeadquartersLEI Field Description Provide the Registration Authority Entity ID of the Ultimate Parent. If Registration Authority ID is Not Available leave blank. Direct Parent exists, but has no registered LEI. Provide the Legal Name of the Direct Parent. Direct Parent exists but has no registered LEI. Provide the Address of the Direct Parent. Direct Parent exists but has no registered LEI. Provide the Country of the Direct Parent. Direct Parent exists but has no registered LEI. Provide the Region of the Direct Parent. Direct Parent exists but has no registered LEI. Provide the City of the Direct Parent. 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. 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. 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. Level 2 Data 10

11 APPENDIX A: 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 State Transition Rules GLEIF Registration Authorities List Associated Reference Documents 11

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