Legal Entity Identifier (LEI) and national identifier
An LEI code can have more than one “registration status”. In which case, should the LEI be reported to AnaCredit?
If no LEI is reported, a national identifier from the predefined list is mandatory, unless otherwise decided by the relevant NCB. What happens if, for a given counterparty, none of the identifiers from the respective country are available? What is reported for counterparties resident in a country which is not present in the list? What happens when there is a change to the “list of national identifiers”?
The “registration status” of an LEI can be any of the following: annulled, cancelled, duplicate, issued, lapsed, merged, pending transfer, pending archival, pending validation, retired, transferred (for details, see www.gleif.org).
For the purpose of reporting a value for data attribute “LEI”, the only relevant LEIs are those whose status is “issued”, “lapsed” “pending transfer”*, “pending archival”* or “merged” (the latter are reported only for reference periods preceding the time the entity was acquired by or merged with another entity, after which the LEI of the surviving/new legal entity is reported). All other cases are treated similarly to the case where no LEI has been assigned to the counterparty, which is why there is also a need to report a national identifier for the counterparty.
If the only available identifier for a counterparty is not in the list of national identifiers published on the ECB’s website, this identifier is still reported to the relevant NCB provided that the identifier in question is publicly available, allows for the unambiguous identification of the counterparty in the country of residence and one of the following conditions is met:
a) the counterparty is resident in a country included in the list and for which the option “other” (identifier type “XX_OTHER_CD”, where XX is the country) is included in the list;
b) the counterparty is resident in a country not included in the list (identifier type “GEN_OTHER_CD”).
In both cases, besides the corresponding identification code itself, a short description of the type of identifier is also reported (e.g. national tax authority registration number) to the relevant NCB.
It is also clarified that, irrespective of the country of residence, reporting an identifier not included in the list, although accepted in some cases (see above), is always considered as the least preferred option.
The list of national identifiers will be updated over time to cover new countries and additional identifiers, based on the experience accumulated with AnaCredit reporting. A national identifier can be reported as soon as it has been added to the list, irrespective of the reference date of the information being reported.
*Q&A updated on the 29th of June 2018