LEI Data
Access and Use LEI Data
ROC Policy on Level 2 Data
Following a public consultation carried out in 2015 by the Regulatory Oversight Committee (ROC), on 10 March 2016, the ROC published the document, entitled ‘Collecting data on direct and ultimate parents of legal entities in the Global LEI System – Phase 1’, which describes the policy design of a process for collecting ‘Level 2’ data on ‘who owns whom’, to complement the existing ‘Level 1’ data on ‘who is who’. Detailed information about this policy is available for download on this page.
In May 2019, the ROC published a policy entitled ‘Policy on Fund Relationships and Guidelines for the registration of Investment Funds in the Global LEI System’, which describes in detail how the ‘Level 2’ data on ‘who owns whom’, are classified according to the fund relationships types. In short, this policy ensures that the relationship data is consistent throughout the GLEIS and provides a means to facilitate a standardized collection of fund relationship information at the global level. Therefore, introduced three new distinct relationship types that can be collected for funds. Detailed information about this policy is available for download on this page.
Collection of data on direct and ultimate parents of legal Entities
The main features of the ROC document are summarized as follows in the report:
- Entities that have or acquire an LEI would report their ‘ultimate accounting consolidating parent’, defined as the highest level legal entity preparing consolidated financial statements, as well as their ‘direct accounting consolidating parent’. In both cases, the identification of the parent would be based on the accounting definition of consolidation applying to this parent.
- Accounting definitions were chosen as a starting point as the ROC concluded that their practical characteristics outweighed limitations caused by the fact that they are designed for a different purpose, i.e., to report relationships to investors on a going concern basis. These practical characteristics are that: (i) they are applicable to both financial and non-financial companies; (ii) their international comparability has increased, following greater convergence between IFRS (International Financial Reporting Standards) and US GAAP (Generally Accepted Accounting Principles) on the scope of consolidation; and (iii) they are widely used, publicly available and their implementation is periodically reviewed by external auditors.
- The information collected would be published in the Global LEI System and therefore freely available for public authorities and market participants. At this stage, the Global LEI System will only record relationship data that can be made public, in accordance with the applicable legal framework.
- Entities would report relationship information to the LEI issuing organizations of the Global LEI System, who would verify the relationship information based on public documents if available (e.g., list of subsidiaries in audited consolidated financial statements; regulatory filings), or other sources.
- Information on parents would be part of the information that must be provided in order for an LEI to be issued or renewed, but with the option of declining to provide this information for the reasons detailed in the ROC’s report.
The Global Legal Entity Identifier Foundation (GLEIF) has developed the organizational and technical standards required to collect data on direct and ultimate parents of legal entities in the Global LEI System.
Fund Relationships and Guidelines for the registration of Investment Funds in the Global LEI System
The main features of the ROC document are summarized as follows in the report:
- Fund Management Entity relationship, defined as a relationship, where a legal entity is considered as the main management entity of a fund when it is legally responsible for the constitution and operation of the fund.
- Umbrella Structures relationship, defined as a legal entity with one or more than one sub-funds/compartments where each sub-fund/compartment has its own investment objectives, separate investment policies and strategies, segregation of assets, separate investors and which has segregated liability between sub-funds/compartments.
- Master-Feeder relationship, defined as a relationship, where a Feeder Fund is exclusively, or almost exclusively, invested in a single other fund (e.g. U.S, EU UCITS), or several funds that have identical investment strategies (for the latter, provided this situation is qualified as a Master-Feeder relationship under the applicable laws and regulations, e.g. some alternative investment funds in the EU) referred to as a Master Fund (or Master Funds).