• Question ID: 2018/0044
• Date of publication: 20/08/2018
• Subject matter: Counterparty reference data
• AnaCredit Manual: Part II
• Data attribute: Legal Entity Identifier (LEI)

Question

Could you please confirm that the Legal Entity Identifier (LEI) or, if an LEI is not available, a national identifier from the list of national identifiers is reported for any counterparty in addition to the (mandatory) counterparty identifier?

Secondly, considering the explanations provided in Part II of the Manual, could you please further clarify the interchangeable use of legal entities, head office undertakings and domestic parts when it comes to the identification of counterparties? How does this relate to the scope of counterparty reference data to be reported depending on which identification perspective is followed? Please consider in particular the relationships with foreign branches, especially as regards the question about which perspective to follow when reporting the counterparty reference data.

Answer

As a general rule, please note that the unique identification of counterparties is an essential feature of AnaCredit. Therefore, as set out in Article 9 of the AnaCredit Regulation, the LEI or, if an LEI is not available, a national identifier from the list of national identifiers (for details of the list of national identifiers, see Section 12.4.3 in Part II of the Manual) is always reported for any counterparty in addition to the (mandatory) counterparty identifier, unless otherwise decided by the relevant NCB. This applies irrespective of the role or residency of the counterparty.

As regards the second question, please note that, in accordance with the clarifications provided in Section 12.1 in Part II of the Manual, in the AnaCredit data model, a legal entity is in fact indistinguishable from its head office/domestic part as far as the identification of counterparties is concerned. Consequently, these terms are often used interchangeably in this regard. However, if a legal entity has one or more foreign branches, the scope of counterparty reference data for legal entities is broader than for their head offices/domestic parts where the counterparty reference data relating to the legal entity are reported also including information relating to the foreign branches, despite the fact that the legal entity is identified by the head offices/domestic parts. Consider for example the data attribute “balance sheet total”, which refers to the legal entity as a whole and, consequently, includes information for all of its foreign branches (if any).

However, as far as counterparty reference data relating to foreign branches (or special funds) are concerned, these data exclusively refer to the foreign branch (or special fund, respectively), while the data of the legal entity are not considered. This is in particular clarified in Table 131 in Section 12.2.1 in Part II of the Manual, which is further enhanced with the following explanations.