How to Prepare for the New ROC Policies

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Ensuring a smooth transition before the introduction on 31 March 2022

By 31 March 2022, the Global LEI System will have implemented three new Regulatory Oversight Committee (ROC) guidelines to further increase the level of open, standardised and high-quality legal entity reference data available to users.

From 1 March 2022, all GLEIF services will accept and display data in new Common Data File (CDF) formats that comply with the new guidelines. Public users of the global LEI system must therefore be able to process data in the new format from this date. The month of March will be used as a transition period during which all LEI-issuing organisations will switch to the new formats and conduct tests to ensure smooth operation. During this month, public users of the Global LEI System should therefore prepare to support both formats when analyzing LEI data. This blog outlines the preparatory steps public users need to take and provides links to more detailed reference information.

Details of the new policies

The new guidelines apply to:

  • Legal Entity Events: Specifies events that change the legal entity or relationship data of an entity or result in the derecognition and/or creation of LEIs.
  • Fund Relationships: Introduces three new types of relationships that can be recorded for funds.
  • Governmental Entities: Allows the classification of certain legal entities as governmental entities or international organisations.

How to prepare for the new policies

The following users must take steps to implement the updated file formats to ensure uninterrupted access to LEI data beyond 1 March 2022:

  • All users of the GLEIF Concatenated files.
  • All users of the Golden Copy and Delta files
  • All users accessing the content of the Golden Copy files via the GLEIF API

GLEIF has published further technical details, sample files and additional documentation specifying the transition steps and the impact on the associated data.

Additional supportĀ 

After 31 March 2022, GLEIF anticipates a period of up to one year before the global LEI system will be fully populated with information on events related to legal entities, fund relationships and government entities. Data will typically be collected at the time of issuance of a new LEI or renewal of an existing LEI.

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