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Regulatory Oversight Committee of the LEI Revises Policy on Level 2 Data Reporting

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The Regulatory Oversight Committee (ROC) of the Global LEI System (GLEIS) has revised two elements of policy covering the reporting of LEI parent relationship data, also known as Level 2 data.

To improve the usability of Level 2 data, the ROC has revised the list of opt-out reasons that can be used by an entity to decline providing information on its parents. The aim of the revision was to consolidate opt-out reasons to facilitate best use of them while retaining the most valuable and used information.

The decision to streamline the list of opt-outs was made at the ROC’s June 2021 meeting and based on statistics from the Global LEI Foundation (GLEIF) that highlighted the most used opt-outs. It resulted in the consolidation of five opt-outs in the ‘non-public’ category into a single opt-out, also called ‘non-public’. The five consolidated opt-outs are binding legal constraint, legal obstacles, disclosure detrimental, detriment not excluded, and consent not obtained.

The resulting ‘non-public’ opt-out joins existing and lasting opt-out categories of natural person(s), no LEI, no known person, and non-consolidating.

The ROC has also decided to discontinue collection of Provisional Node Identifier (PNI) data for parents without LEIs. This decision resulted from a pilot programme that collected metadata on parents without LEIs and assigned these parent entities PNIs as identifiers to supplement Level 2 data collection. The extended Level 2 information was internal to the GLEIS and made available to ROC members for evaluation purposes only.

The ROC recently undertook an analysis of the usefulness of the PNI data for ROC members. It showed that PNI data roughly doubled the information on the parents of LEI registrants available to regulators, but concluded that PNI data collection should be discontinued as the added value of continuing PNI data collection would be outweighed by the cost of cleaning the data to remove duplicates and address other data quality issues.

Instead, the ROC recommends that efforts and resources dedicated to PNI data collection should be redirected to improving the collection and validation of LEI registrants data on their parents, which is a key component of the quality of the LEI data.

You can read more detail about the ROC revisions to reporting LEI parent relationship data here. And we will be back soon with a review of the LEI’s progress through 2021 and the GLEIF’s plans for the identifier through 2022.

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