EIOPA · 42
42
- Regulation
- Guidelines on submission of information to NCAs (Preparatory phase)
- Article
- 35
- Submitted
- 2014-03-13
- Answered
- 2019-10-25
Question
LEI and Pre-LEI:In July 2012 GFMA (Global Financial Markets Association) released a test-file containing a list of entities and the corresponding LEI code.Nowadays designated Pre-LOUs (Local Operating Units) can assign locally Pre-LEI codes to requiring companies. These codes are validated and can be used all over the world.As LEI/Pre-LEI is unique, if a company has both a LEI code of the GFMA test-file and a Pre-Lei code assigned by a Pre-LOU which of the two should prevail for Solvency II purposes?Example:Entity: GRUPPO BANCA LEONARDO SPALEI (GFMA test-file): MCSR9W53J5BQKF4VPL09Pre-LEI (assigned by UNIONCAMERE, italian Pre-LOU): 8156008364FBF7D6E009
Answer
The Pre-LEI concept has been set up pending the operational possibility of having LEI assigned. The GFMA file was ‘a technical test’, not a real LEI by any measure.Limits of use are clearly reminded by GFMA.http://www.gfma.org/initiatives/legal-entity-identifier-(lei)/legal-ent…
“This TEST file is for testing purposes only and not for use in any actual transaction. This TEST file, created by DTCC, contains randomly-selected records pertaining to participants active in the financial markets and consists of 1) a provisional legal entity identifier patterned after the Draft ISO 17442 LEI Standard, and …”
Therefore in the situation described the Pre-LEI (assigned by UNIONCAMERE, italian Pre-LOU) should be used.
This Q&A is published by European Insurance and Occupational Pensions Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.
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