The second stage of the LEI rocket is now being launched! October 19th, a deadline.

The LEI ROC has launched a rocket (euh…sorry, a public consultation) dated September 7th, 2015, on how the GLEIS should start collecting data on direct and ultimate parents of legal entities which have an LEI.

LEIROC Consultation on hierarchies, Sept 2015

Answers to the consultation can be posted until October 19th, 2015. And the subsequent proposed implementation calendar is very ambitious,  as it starts as soon as ‘around the end of 2015’.

So what are the main features of the proposed system? Here is a brief summary of the propositions:

  1. Entities that have or acquire an LEI would report both their ‘ultimate accounting consolidating parent’ AND  their ‘direct accounting consolidating parent’. The extent of the obligation  vs the option to do so is discussed at lenght in the paper, and is a major question to be discussed.
  2. The information would be published in the GLEIS. Again, the extent of the disclosure is discussed at length and deserves careful examination by all the stakeholders.
  3. The LOUs would be required to verify the information based on public documents if avalaible. Another major feature to be discussed.
  4. Finally, the ROC ‘preliminary concludes’ that reporting by the child is the primary option, but that ‘some type of involvement’ by the parent is desirable. Given the fact that some regulators place the brunt of the responsibility on the ‘Group’, rather than on the ‘children’, it is clear that the choice is anything but inocuous, and that it will have a major impact on the internal processes of big global institutions.

The interesting thing about this consultation, as opposed to many others by Regulators, is that it is a real consultation, and not simply an exercice in formal democracy. In other words, the questions don’t bear only on HOW to do what has already been decided by the Regulators, but it bears on the very substance of WHAT should be done, and then how best do it. It is then a real opportunity for all stakeholders to express their point of view, and defend their legitimate interests. So, please, don’t miss the October 19th deadline!

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