GLEIF Now Publishes Four Separate Daily Concatenated Files Containing LEI Records and Related Reference Data Identifying Who is Who and Who Owns Whom
The GLEIF Concatenated Files, which include information on legal entities based on specific reporting formats, are available for download on the GLEIF website, free of charge
Author: Stephan Wolf
Estimated Reading Time: 11 minutes
The ‘Concatenated Files’, published daily by the Global Legal Entity Identifier Foundation (GLEIF), contain the content of the individual files, published by the LEI issuing organizations, which list all LEIs issued to legal entities and related LEI reference data. LEI issuers – also referred to as Local Operating Units (LOUs) – supply registration, renewal and other services, and act as the primary interface for legal entities wishing to obtain an LEI. GLEIF does not modify any of the original source files and performs no data checks.
The business card information available with the LEI reference data, e.g. the official name of a legal entity and its registered address, is referred to as ‘Level 1’ data. It provides the answer to the question of ‘who is who’. Going forward, the LEI data pool will be gradually enhanced to include the ‘Level 2’ data that answers the question of ‘who owns whom’. This data allows the identification of the direct and ultimate parents of a legal entity and, vice versa, in order that the entities owned by individual companies can be researched.
Daily reporting of LEI and legal entity reference data is conducted by the LEI issuing organizations using the Common Data File (CDF) formats. The GLEIF Concatenated Files, which can be downloaded free of charge from the GLEIF website, include specific information on legal entities that have obtained an LEI based on the relevant CDF format. (More information on the CDF formats is included with this blog post in a dedicated section below.)
Since 8 June 2015, GLEIF has published a daily Concatenated File containing Level 1 data for the complete LEI population based on the LEI-CDF format version 1.0. From 8 May 2017, GLEIF will publish three additional daily Concatenated Files which contain the following information, respectively, as made available by the LEI issuers: Level 1 data based on the updated LEI-CDF format version 2.1; relationship data for LEI registrants whose direct and ultimate parents have an LEI and exceptions to the reporting of parent information.
This blog post offers an overview of the information published with the GLEIF Concatenated Files and relevant reporting formats. Sources mentioned in this blog can be accessed via the ‘related links’ below.
Level 1 data provided with the GLEIF Concatenated Files
The LEI-CDF format defines how LEI issuing organizations report their LEI and Level 1 reference data. The standard was originally developed by the LEI Regulatory Oversight Committee (LEI ROC) and mandated for all LEI issuing organizations in August 2014. Subsequently, GLEIF assumed the responsibility for maintaining the standard and developing it further.
Level 1 LEI-CDF Version 1.0 Concatenated File: GLEIF has published the Level 1 LEI-CDF Version 1.0 Concatenated File since 8 June 2015. It contains the Level 1 data, i.e. LEI records and related reference data that provide information on who is who, for the complete LEI population based on version 1.0 of the LEI-CDF format. This is the authoritative source on Level 1 data.
Level 1 LEI-CDF Version 2.1 Concatenated File: GLEIF published the first Level 1 LEI-CDF Version 2.1 Concatenated File on 8 May 2017. It contains Level 1 data based on version 2.1 of the LEI-CDF format as made available by LEI issuers that have achieved LEI-CDF version 2.1 capability. This means: The Level 1 LEI-CDF Version 2.1 Concatenated File does not currently cover the complete LEI population. It is published however, to give LEI data users a preview of how Level 1 data is reported based on version 2.1 of the LEI-CDF format.
In a next step, GLEIF, together with the LEI ROC, will determine the date when all LEI issuers must provide Level 1 data based on the LEI-CDF format version 2.1 without exception. From that date onwards, i.e. when the Level 1 LEI-CDF Version 2.1 Concatenated File will contain the information for the complete LEI population, it will become the authoritative source on Level 1 data.
GLEIF will however, continue to make available both the Level 1 LEI-CDF Version 1.0 and the Level 1 LEI-CDF Version 2.1 Concatenated File for a transitional period of one year until 1 May 2018. This allows the users of LEI data sufficient lead time to adapt processes and operations in line with the LEI-CDF format version 2.1.
The Global LEI Index contains historical and current LEI records including related reference data in one authoritative, central repository. The information made available with the Global LEI Index continues to be based on the data included with the Level 1 LEI-CDF Format Version 1.0 Concatenated File until the Level 1 LEI-CDF Format Version 2.1 Concatenated File becomes the authoritative source on Level 1 data.
The following GLEIF services will continue to be based on the LEI-CDF format version 1.0 for the time being:
GLEIF Data Quality Management Program.
Challenge LEI Data.
We will communicate in due course when these services will be aligned with the LEI-CDF format version 2.1.
Level 2 data provided with the GLEIF Concatenated Files
In March 2016, the LEI ROC, representing public authorities from around the globe, published the policy document titled ‘Collecting data on direct and ultimate parents of legal entities in the Global LEI System – Phase 1’ (see ‘related links’ below). It sets out the principles governing the process of collecting, validating and publishing Level 2 data in the Global LEI System. In December 2016, GLEIF and five ‘first mover’ LEI issuing organizations successfully concluded a prototype exercise to test the end-to-end process of collecting and validating data on the direct and ultimate parents of legal entities that have an LEI. In May 2017, the process of enhancing the LEI data pool, by including Level 2 data to answer the question of ‘who owns whom’, began.
GLEIF now makes available two Concatenated Files providing information related to Level 2 data:
Level 2 Relationship Record (RR) CDF Concatenated File: GLEIF published the first Level 2 RR-CDF Concatenated File on 8 May 2017. Specifically, legal entities that have or acquire an LEI will report their ‘direct accounting consolidating parent’ as well as their ‘ultimate accounting consolidating parent’. The Level 2 RR-CDF Concatenated File contains the Level 2 data based on the RR-CDF format that allows the identification of the direct and ultimate parents of a legal entity whose direct and ultimate parents have an LEI. It is important to note that the information included in the Level 2 RR-CDF 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. It is expected that Level 2 data for the complete LEI population will be available in the course of the first half of 2018, i.e. towards the end of the one-year renewal cycle after the date when collection of Level 2 data started.
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. Exceptions include: The LEI registrant has no parent entity; the child legal entity opts out of reporting for exceptional reasons; the direct and ultimate parents of the LEI registrant do not have an LEI. As is the case with the Level 2 RR-CDF Concatenated File, 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.
The 2008 financial crisis, and more recently, the leak of the Panama papers, has made apparent the importance of increasing transparency in the financial markets. Once parent information for the entire LEI population is available, GLEIF will provide a unique and free data source that allows corporate dots to be connected globally based on open, standardized and high quality LEI data.
Recap: How LEI data is reported – the CDF formats
As mentioned above, the LEI connects to key reference information that enables clear and unique identification of legal entities participating in financial transactions. The International Organization for Standardization (ISO) 17442 standard defines a set of attributes, or legal entity reference data, that comprises the most essential elements of identification. The CDF formats provide the specificity needed for the operational implementation of the ISO standard. External standards have been included in the CDF formats, where appropriate, to promote data quality.
The reporting of Level 1 and Level 2 data, respectively, is based on specific formats:
Level 1 – LEI-CDF format: Defines how Level 1 data, i.e. the information on ‘who is who’, is reported.
Level 2 – Relationship Record CDF (RR-CDF) format: Defines how Level 2 data, i.e. information on ‘who owns whom’, is reported for LEI registrants whose direct and ultimate parents have an LEI.
Level 2 – Parent Reference Data format: Defines how reference data for parent entities without an LEI is stored and transferred between LEI issuers and GLEIF. As determined with the LEI ROC policy paper ‘Collecting data on direct and ultimate parents of legal entities in the Global LEI System – Phase 1’ , 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.
Level 2 – Reporting Exceptions format: If the child legal entity reports an exception, a record in this format is generated for the parent entity. Each record refers to a child legal entity, indicates whether the exception applies to the direct or ultimate parent and provides the reporting exception.
Each reporting format is defined in a detailed specification document and an XML schema definition (XSD) which enforces minimum data quality. A file which does not pass XSD validation cannot be included in the GLEIF Concatenated Files and the Global LEI Index. The schema defines:
The structure of each data element.
The associated code lists.
The associated data element attributes.
The technical specification documents also contain concise definitions of the data elements. These specifications are available for download on the dedicated GLEIF website pages included in the ‘related links’ below.
GLEIF will periodically review the CDF formats to identify the need for updates based on new or adapted policies introduced by the LEI ROC and to align with user requirements.
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Stephan Wolf is the CEO of the Global Legal Entity Identifier Foundation (GLEIF). Since January 2017, Mr. Wolf is Co-convener of the International Organization for Standardization Technical Committee 68 FinTech Technical Advisory Group (ISO TC 68 FinTech TAG). In January 2017, Mr. Wolf was named one of the Top 100 Leaders in Identity by One World Identity. He has extensive experience in establishing data operations and global implementation strategy. He has led the advancement of key business and product development strategies throughout his career. Mr. Wolf co-founded IS Innovative Software GmbH in 1989 and served first as its managing director. He was later named spokesman of the executive board of its successor IS.Teledata AG. This company ultimately became part of Interactive Data Corporation where Mr. Wolf held the role of CTO.