Understanding LEI Status

Every LEI has not one, but two statuses associated with it. These statuses change over a legal entity’s lifecycle and often have critical implications for regulatory compliance and risk management. To appreciate these implications, you need to understand the different status values.

In this post we define each status, describe the values each can assume and provide stats on the current distribution of these values across the LEI universe. We discuss the relationship between the two statuses and list the reasons a status can change. We then look at the specific compliance and risk implications of status changes, and the need to proactively monitor them.

Entity Status

An LEI’s entity status indicates whether the legal entity the LEI references is legally registered and operating. It always assumes one of the two values in the below table. The figures in Table 1 and throughout this post are current as of February 26, 2018.

Table 1: Entity Status Values

The reason why an entity has become INACTIVE is captured in the LEI’s registration status.

Registration Status

The registration status of every LEI appearing in the publicly available LEI data always assumes one of the eight values in Table 2.[i]

Table 2 Registration Status Values

Relationship to Entity Status

As Table 2 indicates, there is a well-defined relationship between an LEI’s registration status and its entity status. An LEI’s entity status is INACTIVE if and only if its registration status is either MERGED or RETIRED.

You can find the rules defining the relationship between these two statuses, as well as many other data validation rules, in the State Transition Rules for LEI-CDF.

Status Updates

Entity and registration status updates, detailed below, occur due to corporate actions or processing events.

LEI Issuance

New LEIs have an entity status of ACTIVE and a registration status of ISSUED.

Overdue LEI Renewal

The registration status of an LEI not renewed by its renewal date changes from ISSUED to LAPSED. The registration status of an LEI renewed after its renewal data changes from LAPSED to ISSUED.[ii]

Merger

The merger of a legal entity into another such that it ceases to exists as a separate entity results in its LEI’s entity status to update to INACTIVE and its registration status to MERGED.

Retired

When a legal entity ceases to operate for a reason other than a merger, such as bankruptcy or dissolution, its LEI’s entity status is updated to INACTIVE and its registration status to RETIRED.

Duplicate

If two or more LEIs mistakenly are issued for the same legal entity, the registration status of all but one LEI will be updated to DUPLICATE.[iii]

Annulled

An LEI’s registration status is set to ANNULLED if it is determined the LEI was issued in error for a reason other than duplication.

Transfer

A registration status of PENDING_TRANSFER or PENDING_ARCHIVAL indicates a transfer from one LEI issuer (LOU) to another.[iv]

Compliance & Risk Implications

Lapsed LEIs

Ensuring your firm’s own LEIs are duly renewed is a requirement of some regulations including MiFID II and the latest version of EMIR.

If your firm has a small number of LEIs, meeting the renewal requirement is straightforward. On the other hand, prompt LEI renewal may create a data management challenge for a large bank with thousands of LEIs representing its entities.

Regulations do not currently require you to verify the renewal of client and counterparty LEIs, but they do require use of the correct LEI. This means you must not only ensure the LEI references the party in question but also that the LEI has a registration status of ISSUED, LAPSED, PENDING_TRANSFER or PENDING_ARCHIVAL.

Any other registration status implies a successor LEI should be used instead, or that the legal entity is RETIRED and can’t transact.

Successor LEIs

LEIs with a MERGED or DUPLICATE registration status will have an associated successor LEI. In the MERGED case, the successor LEI represents the entity that has absorbed the original; for the DUPLICATE, the successor is the one surviving LEI.

If you map accounts to LEIs, you’ll need to update the mapping for a MERGED or DUPLICATE entity to use the successor LEI. It’s the successor LEI that should be referenced in future trade and transaction reports submitted to regulators. Such mapping updates also facilitate the correct calculation of exposures for risk management purposes.

Retired LEIs

In the instance of an LEI that is RETIRED, there will be no successor, but it still may trigger an event in your system. For example, you may need to disable accounts that reference an LEI with a registration status of RETIRED. Such LEIs of course should not be referenced in future trade or transaction reports.

Historical Record Retention

The global LEI system retains records with MERGED, RETIRED, DUPLICATE or ANNULLED registration status for query resolution and historical reasons. These records continue to appear in data published by LOUs and the GLEIF.

To keep your LEI mappings correct and compliant, it is not enough to simply load and reference the most recently published LEI data. This data must also be proactively monitored for the sorts of changes discussed above and you must update your system in response.

Impact of MiFID II on Status

Since all new registrations have an ACTIVE entity status and an ISSUED registration status, the recent doubling of the LEI population due to MiFID II-related registrations has inflated the percentage of LEIs with these statuses.

Over 4.3% of the LEIs registered prior to 2017, before the MiFID II surge, have an INACTIVE status. It’s likely the percentage of LEIs with an INACTIVE status will increase in the coming years, and the same can be said for the registration status values of LAPSED, RETIRED or MERGED.

Conclusions

As we’ve shown, changes in LEI status are a result of the natural lifecycle of a legal entity and may have important regulatory or risk implications for your firm.

Understanding LEI statuses is a prerequisite for effective LEI data management. A one-time mapping of accounts to LEIs will become stale over time - and therefore incorrect and non-compliant. Status changes must be monitored and acted upon to maintain up-to-date mappings.

[i] The table does not include the PENDING_VALIDATION, CANCELLED and TRANSFERRED registration status values. Though these values appear in the LEI documentation, they’re not included in public LEI data. LOUs use these values for internal processing; therefore, they are not relevant to our discussion.

[ii] LEI renewals occur on an annual basis to ensure LEI reference data is up to date. A small renewal fee helps defray the cost of the global LEI system.

[iii] While LOUs are required to check for duplicates during registration, with over 30 LOUs it is possible for accidental creation of duplicates. For example, two parties may simultaneously register the same LEI at two different LOUs.

[iv] Since LEI records require ongoing maintenance and renewal, registrants have the option to transfer an LEI from one LOU to another for reasons such as cost or quality of service.