The Regulatory Oversight Committee (ROC) of the Global Legal Entity Identifier System (GLEIS) has addressed the need for a common data format that can be used by all pre-Local Operating Units (LOUs) with a set of basic data elements. It has also endorsed more pre-LOUs, bringing the total to 12.
The basic data elements of the common data format are the first part of a development that will lead to a more detailed technical specification. The second part of the development, which will provide more precise specification of the content, range and high-level technical design of pre-LEI data records, is expected to be complete and ready for use when the interim GLEIS transitions into the Global LEI System. The ROC does not disclose when this will be, but does note that a deadline will be set for endorsed pre-LOUs to introduce and publish the common data file. The deadline, says the ROC, will be set ‘in recognition of market and technology needs’.
The ROC acknowledges market and pre-LOU demand for a common data file, explaining: “The absence of a common data format across pre-LOUs adds complexity to the task of avoiding exclusivity violations (more than one pre-LEI per entity) and difficulties for users uploading data from multiple pre-LOUs into their systems.”
The work was divided into two parts to meet demand for rapid progress. The first part of the work announced by the ROC was undertaken by the LEI ROC Committee on Evaluation and Standards in collaboration with the Private Sector Preparatory Group, nominees of the board of directors of the Global LEI Foundation, pre-LOUs and other stakeholders.
It covers the basic elements of the common data format, which are set down in a table entitled Information content of the common file. The table covers: information required by ISO 17442:2012 and closely linked information; additional status information that is important to the interpretation of the data; and other information judged necessary to address differences across pre-LOUs or the needs of their jurisdictions in the interim GLEIS.
The ROC says the second part of the work is expected to add technical detail to the basic elements and, when complete, will provide a framework to support the initial roll out of the GLEIS. This is a significant statement by the ROC and the first real indicator of transition from the interim to the full global system, but the ROC does warn: “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.”
As well as outlining a much needed common data file, the ROC has recently endorsed a number of pre-LOUs, making the LEIs they allocate globally acceptable to the ROC for reporting purposes. Four pre-LOUs have been endorsed in January and February 2014, namely: the Dutch Chamber of Commerce, sponsored by the Netherlands Authority for the Financial Markets; the National Board of Patents and Registration of Finland, sponsored by the Financial Supervisory Authority of Finland; Centrální depozitá? cenných papír?, sponsored by Czech National Bank; and Unione Italiana per le Camere di Commercio, Industria, Artigianato e Agricoltura, sponsored by Banca d’Italia and Commissione Nazionale per le Società e la Borsa. These additions bring the total number of endorsed pre-LOUs to 12. The total number of pre-LOUs that have been allocated a four digit prefix by the ROC is 21, of which seven are not yet operational.
The increasing spread of endorsed pre-LOUs and the ROC’s effort to solve operational data problems within the interim global LEI system signal significant progress in creating a stable and global legal entity data scheme. But what do these advances mean to practitioners who are already working with the LEI and what impact will the global system have on the market as a whole? These are some of the entity data management issues that will be up for discussion in a session at next week’s Data Management Summit that will cover not only the LEI, but also how it is being used by market participants that must comply with European Market Infrastructure Regulation and where it is expected to turn up next.