The lifecycle of a Legal Entity Identifier
The lifecycle of a legal entity identifier can be determined from the 'RegistrationStatus' attribute stored by the Local Operating Unit (LOU).
If a legal entity registers, receives an LEI, never undergoes a corporate action or never transfers to another LOU, the ISSUED status should be the only registration status a user should see against their LEI in a LOU's published file.
If the legal entity ceases trading then a status of RETIRED is assigned and if the legal entity is involved in a merger or acquisition by another legal entity then the registration status of MERGED is set. These two states should be the final two possible for a legal entity but should still be part of the published files from the LOUs.
PENDING_VALIDATION is an internal flag and so should not be seen by a user of the GLEIS as the LEIs should be fully validated prior to them being issued and published.
On an annual basis there is a need for an LEI to be re-certified, the registration status code LAPSED distinguishes between LEIs that are up to date and those whose renewals are overdue and require maintenance.
There are three registration status associated with registration errors: DUPLICATE, ANNULLED, and CANCELLED.
The DUPLICATE code refers to the non-surviving record of an identical matching record. The ANNULLED code applied to any other type of assignment error detected post an LEI registration has been publicly issued. The CANCELLED code refers to any type of assignment error detected prior publication.
These error states are terminal, i.e. no further updates are expected to occur. Records in the DUPLICATE or ANNULLED states should occur in published records, CANCELLED records are retained internally by an LOU to support auditing.
Set out in recommendation 5 of the FSBs recommendations to the G-20 on how to implement a global Legal Entity Identifier system (GLEIS) it states "the LEI should be portable", that is the management of an LEI can be transferred from one LOU to another LOU. To accommodate this transfer there are 3 statues: TRANSFERRED, PENDING_TRANSFER, and PENDING_ARCHIVAL.
In the transitional period between the transfer request and the confirmation of the transfer there are two statuses: PENDING_TRANSFER and PENDING_ARCHIVAL. There is a risk that a given LEI might appear simultaneously in two published files from two different LOUs: once in the "sending" LOU's published file with a registration status of PENDING_ARCHIVAL and also in the "receiving" LOU's published file with a registration status of ISSUED. The issuing or sending LOU should finally set the status of the transferred record to TRANSFERRED after the receiving LOU successfully receives the transfer.
|Category||Record Publication State||RegistrationStatus Value|
Internal: the LEI record is not included in the public file published by the managing LOU, but may be exchanged between LOUs as part of the validation process prior to issuance
Published: the LEI record is included in the public files published by the managing LOU
Transient: the LEI record is included in the public file published by the managing LOU, only for a transient period during a record transfer from one LOU to another
Archived: the LEI record is not included in the public file published by the managing LOU, it is retained by the managing LOU as part of its archival records
Derived from: LEI Data File Format 1.0