[Spike] Confirm which actions a user can perform with a lapsed LEI

[billhimmelsbach]

What can actions can a user perform on the platform with a lapsed LEI? (formerly known as inactive LEI)

Can a user...

• register with the platform
• log into the platform
• start filing
• upload a register file
• submit their filing

Some related questions as well:

• If a user logs in right before the filing deadline, has submitted an accurate SBLAR and given us their accurate financial institution information, but that user's institution has an inactive LEI, should they not be allowed to file?
• What should the restrictions be for the beta vs production?
• Do we only care about a user's current LEI status, not their historical LEI status at the end of the activity period?
  • Sounds like we've solved this one since we cannot get historical lei status from the GLIEF API, so we wouldn't have a way to determine when their LEI was lapsed

[Kibrael]

Our last discussion on this is in the SBL Decision doc (link redacted)

LEI Status

How shall we handle lapsed LEI status?

Does this scenario work:

• Allow use of Beta with banner notification indicating LEI is lapsed and will need to be updated prior to submitting data on Prod
• Stop users from submitting data on Prod, but allow other features
• Does SBL Help have lapsed LEI collateral? (yes)

Some Facts (@nongarak please confirm I am correct)

• LEI status is available as current only. There is not historic data publicly available on ranges of active or inactive status.
• The submission of certified data is a special trigger in the regulation

Tasks for Data Products (@nongarak @Kibrael )

• [ ] Get answers to the above and below questions
• [ ] Does the Regulation have rules specific to LEI status?

[nongarak]

Most of discussion moved to [Enterprise]/sbl-data-collection/issues/757.

I will point out here in public land that there is always access to the Golden Copy of historic LEI data for a specific day, so we can in fact see what the status was on 12/31 of a given activity year. This is not accessed by the API but is a static file available for download from the GLEIF website daily.

[nongarak]

Some details on how the Golden Copy works, per our GLEIF contact:

Our Golden Copy tracks record modifications and provides this information in LEI Search under the 'Events and Changes' tab (e.g., https://search.gleif.org/#/record/549300ATMBC7M8RHFG89/record_modifications).

A good way to retrieve this information is probably the GLEIF API which includes a dedicated endpoint for modification data. This endpoint also allows to filter the response, for example by selecting only modifications in selected fields or before/after a specific date.

For your use case (tracking changes in RegistrationStatus), you can send GET requests to: https://api.gleif.org/api/v1/lei-records/549300ATMBC7M8RHFG89/field-modifications?filter[field]=/lei:LEIData/lei:LEIRecords/lei:LEIRecord/lei:Registration/lei:RegistrationStatus (replace the LEI code for other entities). No login or credentials are required. You can also open the above link in a browser.

The response is JSON formatted. Here is a relevant part with the information on field changes:

The first entry indicates an update in RegistrationStatus from PENDING_ARCHIVAL to LAPSED on 2023-08-03. The second one from PENDING_TRANSFER to PENDING_ARCHIVAL on 2023-08-01. The date timestamps mark the date when the data was updated in the Golden Copy. With that, you can track periods, the new value would be the 'current' one from the modification date onward until the next update (or until today, if there are no further updates). Per default, modifications are sorted as latest/most recent first.

There are three other modificationTypes besides UPDATE: • INITIAL (when the LEI record enters the GC for the first time) • INSERT (when a previously empty field is populated for an existing record) • DELETE (when the content of a field is removed) For more details, please see the respective section in the API documentation: https://documenter.getpostman.com/view/7679680/SVYrrxuU?version=latest#73a27773-16f1-45fd-8ce2-2c40d5ac789d

Please note, the Golden Copy was created in early 2018. All records issued before have an INITIAL import from that time and modifications before that date are not tracked.

[natalia-fitzgerald]

@dan-padgett There is some important information here that will be relevant to our upcoming activity period discussions. I will compile the relevant links before closing this ticket.