The Regulatory Oversight Committee (ROC) of the Global Legal Entity Identifier System (GLEIS) has published the second part of a common data file format for pre-Local Operating Units (LOUs). This follows the introduction in February 2014 of a first common data file format for pre-LOUs to use in publishing LEI data or communicating with other pre-LOUs.
The second part of the common data file adds more precise technical specifications to express the content set noted for the LEI in the first part. But it fails to include hierarchy data that many market participants say is essential to aggregating data and identifying risk exposure. This is so despite a statement from the ROC accompanying the release of the first part of the common data file format, saying: “The ROC wishes to emphasise that the GLEIS will evolve over time in response to the needs of the regulatory community and private sector users, for example to incorporate additional reference data, such as data on ownership and hierarchical relationships as previously highlighted.”
While direction on hierarchy data remains elusive, the second part of the common data file format, or LEI Data File Format 1.0, must be adopted by endorsed pre-LOUs for publication of their LEI information by August 19, 2014. Pre-LOUs seeking endorsement to join the interim GLEIS must also commit to using the common data file by the same deadline.
In its framing note on part two of the common data file format, the ROC states: “As the GLEIS high level principles stipulate, the GLEIS should uniquely and unambiguously identify participants to financial transactions. The ISO 17442 standard defines a set of attributes that are the most essential elements of identification, but this structure alone is necessarily coupled with greater specificity given the federated model for the GLEIS. First, the semantic content of those attributes must be fully specified. Second, some additional elements, such an indication of the status of the information, are necessary for effective use of the data. Third, the form the information takes at any given pre-LOU must be such that it can be made to conform to a common standard, which must also be specified. The common data file format provides the additional standards necessary in these areas to support the interim GLEIS, particularly in maintaining exclusive assignment of pre-LEIs and identifying [and] remediating data quality issues, and supporting use of the data.”
Part one of the common data file was written in response to demand from market participants, data users and pre-LOUs as the lack of a common data format across pre-LOUs added complexity to avoiding LEI exclusivity violations, created data disparities and raised technical difficulties for users uploading data from multiple pre-LOUs into their systems.
The second stage development of a common data file format was undertaken by a working group composed of members of the ROC’s Committee on Evaluation and Standards and other technical experts. The resulting LEI Data File Format 1.0 was then subject to comments from members of the Private Sector Preparatory Group and pre-LOUs, before being endorsed by the ROC.
Changes to the content of the common data file format set down in part one are minimal and include: a resolution to the problem of an entity expiring as the result of
a merger and its successor entity not having an LEI; the inclusion of an associated entity field to support the identification of umbrella funds and similar fund structures – the ROC says it will publish more guidance on the identification of funds in due course; a move to make LEI reference data closer to full compliance with ISO 17442 by including more complete information about business registries; and a reformulation of the classification proposed for establishing the status of a registered entity and its LEI.
The ROC concludes the framework note stating: “The common data file format provides a detailed technical description of the structure of each data element and the associated code lists and attributes. External standards have been included, where appropriate, to promote data quality. The document also provides both an XML schema as the formal representation of the underlying information and a description of how change of the common data file format should be managed from a technical perspective.”
An updated table detailing content of the common data file format is annexed to the ROC’s second framing note A Common Data File Format for Pre-LOUs, Part 2 : Framing Note, and the technical specification of the LEI Data File Format 1.0 can be found here.