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How to Prepare for the New ROC Policies

Ensure a smooth transition ahead of the implementation on March 31, 2022

Author: Stephan Wolf

  • Date: 2021-05-31
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By March 31, 2022, the Global LEI System will have implemented three new Regulatory Oversight Committee (ROC) policies to further increase the level of open, standardized, and high-quality legal entity reference data available to users.

From March 1, 2022, all GLEIF services will accept and display data in new Common Data File (CDF) formats in line with the new policies. Public users of the Global LEI System will therefore need to be able to process data in the new format from this date onwards. The month of March will be used as a transition period during which all LEI issuing organizations will migrate to the new formats and perform testing to ensure smooth operations. During this month, therefore, public users of Global LEI System should prepare to support both formats when performing LEI data analysis. This blog outlines the preparatory steps public users are required to take and provides links to more detailed reference information.

Details of the new policies

The new policies apply to:

  • Legal Entity Events: Specifies events that alter the entity, the relationship data of a legal entity, or result in the retirement and/or creation of LEIs.
  • Fund Relationships: Introduces three new distinct relationship types that can be collected for funds.
  • General Government Entities: Allows certain legal entities to be classified as Government Entities or International Organizations.

How to prepare for the new policies

The following users must take action to implement the updated file formats to ensure uninterrupted access to LEI data beyond March 1, 2022:

  • All users of the GLEIF Concatenated files
  • All users of the Golden Copy and Delta files
  • All users who access the content of the Golden Copy files via the GLEIF API

GLEIF has published further technical details, example files and additional documentation specifying the transition steps and the impact on associated data here.

Additional support

Following March 31, 2022, GLEIF anticipates a period of up to one year before the Global LEI System will be fully populated with information on Legal Entity Events, Fund Relationships and Government Entities. Data is generally collected at the time of new LEI issuance or existing LEI renewal.

If you have questions or need additional support ahead of the March 1 deadline, please email GLEIF:

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About the author:

Stephan Wolf is the CEO of the Global Legal Entity Identifier Foundation (GLEIF). Between January 2017 and June 2020, Mr. Wolf was 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.

Tags for this article:
Data management, Global LEI Index, Global Legal Entity Identifier Foundation (GLEIF), Open data, Common Data File Formats, Regulatory Oversight Committee (ROC)