Level 2 Data: Parent Reference Data 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’.
Distinct procedures apply regarding direct and ultimate parents with and without an LEI.
If the direct and / or ultimate parents of an LEI registrant do not have an LEI, the following applies: The child legal entity will be obliged to report reference data on its direct and ultimate parents to the LEI issuing organization in accordance with the document, titled ‘Parent Reference Data Format’. This document defines the technical format which specifies how reference data for parent entities without an LEI is stored and transferred between LEI issuers and the Global Legal Entity Identifier Foundation (GLEIF). The Parent Reference Data format is based on the existing LEI Common Data File (LEI-CDF) format version 1.0.
GLEIF published the document ‘Parent Reference Data Format’ version 1.0 in November 2016 for information. In May 2017, GLEIF published a further update: Parent Reference Data 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 Parent Reference Data 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 Parent Reference Data format requires the following data elements to be provided by the legal entity for its direct and ultimate parents that do not have an LEI:
- Legal Name.
- Legal address.
- Headquarters address.
- Business register information (if applicable): Identification of the register and registry number for the parent entity.
Other valid LEI-CDF format data elements may be provided together with the parent reference data if the LEI issuing organization wishes, but this is optional.
During an initial phase, the reference data reported by a child entity for its direct and ultimate parents without an LEI will not be published.
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) specifies with regard to direct and ultimate parents of LEI registrants that do not have an LEI: Initially, “the public reference data of the child entity would only mention that there is a parent, but that the parent does not consent to have an LEI or could not be contacted.” Three specific rules would apply to the data collected on parents without LEIs (parent metadata):
- “There would be no other verification of the parent metadata than the documents already used to establish the relationship, to avoid excessive costs to the Global LEI System compared to the situation where the parent LEI is provided.” This information would help LEI issuers verify, at least on an annual basis, that the parent does not have an LEI unknown to the child.
- “The absence of publication of the parent metadata and of relationships between child entities based on this parent metadata, would provide additional time to review, based on real cases, whether publication would harm the Global LEI System, including concerns that this lower quality data may affect the reputation of the Global LEI System and the adoption of the LEI.”
- For as long as metadata on parents will not be published, this data will only be accessible to GLEIF and LEI ROC members.
The LEI ROC policy further clarifies that no later than six months after the start of the effective collection of relationship data by LEI issuing organizations, the LEI ROC “will determine whether the parent metadata can be made public as part of the reference data of the child” or whether additional time would be required “to address any issues associated with publication, with the expectation that publication will take place as soon as feasible.”
For information regarding relationship information for LEI registrants whose direct and / or ultimate parents have an LEI, refer to this dedicated GLEIF website page: Level 2 Data: Relationship Record (RR)-CDF Format.
Please address questions on the Parent Reference Data format to firstname.lastname@example.org.
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