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]

Per 109(b)(6)-1 in the rule:

A financial institution complies with § 1002.109(b)(6) by reporting its current LEI number. A financial institution that does not currently possess an LEI number must obtain an LEI number, and has an ongoing obligation to maintain the LEI number.

From the preamble to the rule, page 544:

Financial institutions also have an ongoing obligation to maintain their LEI number. As part of maintaining an LEI number, a financial institution must make sure the LEI number and associated information are current, including any relationship data.

Nowhere in the rule do they define LEI status in the sense that GLEIF defines Registration Status. I will reach out to Regs about what they think but FWIW I think 'maintain' and 'current' implies institutions must have an 'ISSUED' status with GLEIF, at the very least for submission.

Here is a blog on GLEIF LEI registration/renewal if it's helpful.

I can also reach out to GLEIF to confirm the answer to the question about historical LEI status, but I do not believe it is captured in the dataset explicitly. However, GLEIF does maintain the "golden copy" of the entire GLEIF dataset, which is a snapshot of the entire dataset every day. So for a given day we can always go back to the archive and check the status (I'm sure this could be automated via the GLEIF API and our own postgres dumps).

[Kibrael]

My read is the same as @nongarak

[dan-padgett]

That blog post was insightful @nongarak. With regard to status, what stood out to me was this paragraph: "It must be stressed however, that a lapsed LEI remains valid. The status ‘lapsed’ in the relevant data field of an organization’s LEI reference data simply indicates that it is behind schedule as regards renewal, i.e. re-validation of its information against third party sources."

And it sounds like the idea of "maintaining" an LEI (as the rule puts it) is likely related to ensuring that the "information recorded for the legal entity" (i.e. name and address) has been verified.

If I'm drawing the right conclusion, then having a "lapsed" LEI is really just a flag on our end that the data associated with an LEI might be outdated. If that's correct, then showing an LEI as lapsed in our system could just mean we provide some extra guidance to double check the information associated with the LEI. But because the LEI is still valid, I don't see it as any more of a blocker to filing than any other information on sign and submit that is incorrect.