Identifiers in cases where a creditor sells an instrument to another creditor
How should identification codes be applied where a creditor sells an instrument to another creditor, but the contract and the instrument remain unchanged?
Annex IV to the AnaCredit Regulation stipulates that each reporting agent must use a unique contract identifier to identify each contract and a unique instrument identifier to identify each instrument belonging to the respective contract. Please refer to Section 2.2.4 of Part II of the AnaCredit Manual for more information.
However, with the exception of the syndicated contract identifier, the AnaCredit Regulation does not require two different reporting agents to use the same contract identifier, even if it refers to the same credit agreement or loan. In particular, the transferee is not required to use the same contract and instrument identifiers as the transferor in the event of a loan being sold. Indeed, such a requirement could interfere with the requirement for each contract/instrument identifier combination to be unique at reporting agent level.
Please note, however, that if a loan transfer takes place across different observed agents of the same reporting agent, the loan’s contract and instrument identifiers would be expected to remain unchanged, given the provisions of the AnaCredit Regulation regarding the contract identifier.
At the same time, it is not a problem for the transferee to use the contract and instrument identifiers that were applied by the transferor, provided that this does not conflict with the requirement for the transferee to uniquely identify all contracts and all instruments under the respective contract.