Level 2 Data: Reporting Exceptions Format
In May 2017, the process of enhancing the Legal Entity Identifier (LEI) data pool, by including ‘Level 2’ data to answer the question of ‘who owns whom’, began. Specifically, legal entities that have or acquire an LEI will report their ‘direct accounting consolidating parent’ as well as their ‘ultimate accounting consolidating parent’.
Records in the Reporting Exceptions format refer to a child legal entity and its direct or ultimate parent and mention the type of reporting exception. Reporting exceptions are:
- There is no parent entity.
- The child legal entity opts out of reporting for exceptional reasons (see below).
- Parent entities do not have an LEI.
GLEIF published the document ‘Reporting Exceptions Format’ version 1.0 in November 2016 for information. In May 2017, GLEIF published a further update: Reporting Exceptions format version 1.1. The detailed technical specification document and the corresponding XML schema definition are available for download at the foot of this page. Changes introduced in version 1.1, compared to the Reporting Exceptions format version 1.0, are minor and backwards compatible. These changes are detailed in section 1.7 (‘Release Notes’) of the technical specification document available below.
The GLEIF Concatenated Files, which are available for download, include specific information on an LEI record and related reference data based on the relevant reporting format.
- Level 2 Reporting Exceptions Concatenated File: GLEIF published the first Level 2 Reporting Exceptions Concatenated File, based on the Reporting Exceptions format, on 8 May 2017. It is important to note that the information included in the Level 2 Reporting Exceptions Concatenated File does not yet cover the complete LEI population for the following reason: The collection and validation of Level 2 data by the LEI issuing organizations for LEIs that existed prior to May 2017 takes place with the annual renewal of the LEI. Renewal means that the reference data connected to an LEI is re-validated annually by the managing LEI issuer against a third party source. The content of the Level 2 Reporting Exceptions Concatenated File will be gradually enhanced and should be completed during the first half of 2018 as LEI issuing organizations collect Level 2 information for LEIs that were issued prior to May 2017 during the one-year renewal cycle.
In its policy paper, titled ‘Collecting data on direct and ultimate parents of legal entities in the Global LEI System – Phase 1’, the LEI Regulatory Oversight Committee (LEI ROC), defines the option to decline providing parent information for the reasons listed in section 3.3.1 of the LEI ROC’s paper.
Section 3.3.1 states, among other things, that the LEI ROC considers that there should only be the following limited list of reasons for an entity to decline providing information on its parents, knowing that the adequacy of the list will be reviewed by the LEI ROC “as needed in light of experience”:
- There is no parent according to the definition used: this will include for instance (i) the entity is controlled by natural person(s) without any intermediate legal entity meeting the definition of parent in the Global LEI System; (ii) the entity is controlled by legal entities not subject to preparing consolidated financial statements (given the definition of parents in the Global LEI System); (iii) there is no known person controlling the entity (e.g., diversified shareholding).
- Legal obstacles prevent providing or publishing this information: this will include (i) obstacles in the laws or regulations of a jurisdiction; (ii) other binding legal commitments such as articles governing the legal entity or a contract.
- The disclosure of this information would be detrimental to the legal entity or the relevant parent. This will include reasons generally accepted by public authorities in similar circumstances, based on a declaration by the entity.
Please address questions on the Reporting Exceptions format to firstname.lastname@example.org.
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