Question ID:
2013_582
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Large Exposures
Article:
394
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Article/Paragraph:
5. LE1 template: Identification of the counterparty
Disclose name of institution / entity:
No
Type of submitter:
Credit institution
Subject Matter:
LE1 column 030 ('LEI code')
Question:

What does the legal entity identifier exactly mean? Does it mean LEI applicable in the reporting country?

Background on the question:

For example: currently in Poland in the national reporting system we use REGON code for Polish counterparties and EKZ code (Registration for Foreign Clients code) for foreign counterparties. We do not use the original Company Registration Number for foreign counterparties.

Date of submission:
29/11/2013
Published as Final Q&A:
11/04/2014
Final Answer:

LEI code (column 030 in template C 27.00) stands for Legal Entity Identification code. It is a reference code proposed by the Financial Stability Board (FSB) and endorsed by the G20, aimed at achieving a unique and worldwide identification of parties to financial transactions.

The global LEI system is not yet fully operational. However, as an interim solution, a system of pre-LEI codes has been introduced. Pre-LEI codes may be assigned to counterparties by any pre-LOU (pre-Local Operational Unit) that has been endorsed by Regulatory Oversight Committee (ROC, detailed information may be found at the following website: www.leiroc.org). When a pre-LEI code (which is assigned by a recognised pre-LOU) exists for a given counterparty, it should be used in {C 27.00, c030} to identify that counterparty. This would prepare for the full implementation of the LEI system since the pre-LEI codes, as long as they are assigned by a recognised pre-LOU, will become LEI codes.

Meanwhile, when the LEI (or pre-LEI) code of the counterparty is missing, {C 27.00, c030} will be left empty but the institutions should report in column 010 of that template the code of the group of connected clients or of the individual counterparties according to the national reporting system.

The same applies to {C 06.00, c025} and to {F 40.01, c010} regarding entities within the consolidated group.

Reference to the case of Poland.

In Poland there is already a pre-LOU (KDPW S.A.), that had not yet been endorsed by ROC at the date of writing the present answer. KDPW S.A. already assigned pre-LEI codes. However, these codes may be used for regulatory purposes only after ROC endorses KDPW S.A. as globally recognised pre-LOU. The ROC decision regarding KDPW was expected by the end of 2013 or at the beginning of 2014.

Meanwhile, the institutions should report in column 010 of that template the code of the group of connected clients or of the individual counterparties according to the national reporting system. In the case of Poland, it means respectively REGON code (statistical number for business units) and PESEL code (Polish Resident Identification Number for individual clients) for domestic counterparties and EKZ code (Registration for Foreign Clients) foreign counterparties.

 

Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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