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#2126164 - 04/13/17 02:11 PM Re: Loan Entity Identifier Truffle Royale
Truffle Royale Offline

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No matter who you use, they're going to be going to the GMEI Utility to get the number.
The LEI is a GLOBAL Legal Entity Identifier. That's why the utility for the number is located in the Netherlands. Additionally, I've heard the bill comes out of Switzerland.
Kathleen Blanchard wrote this about the LEI:
The CFPB chose to use an existing legal entity numbering system to replace the various IDs currently in use as Respondent IDs for HMDA reporting. The LEI process was not developed just for HMDA.

The Global Markets Entity Identifier (GMEI) utility is DTCC’s (Depository Trust & Clearing Corporation) legal entity identifier (LEI) solution. The solution was designed to create and apply a single, universal standard identifier to any organization or firm involved in a financial transaction globally and was developed in response to the financial crisis of 2008- 2009 after governments and regulators called for new financial market regulation.
The CFPB did not “cook this up” solely for HMDA!


I'll be going straight to GMEI to get our LEI.

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#2126168 - 04/13/17 02:24 PM Re: Loan Entity Identifier Truffle Royale
Ski Offline
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Posts: 639
South Louisiana
Totally agree!

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#2126174 - 04/13/17 02:46 PM Re: Loan Entity Identifier Truffle Royale
City Girl Offline
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Posts: 149
Midwest
Thank you.

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#2126176 - 04/13/17 03:16 PM Re: Loan Entity Identifier City Girl
Sinatra Fan Offline
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Cusip Global Services provides LEIs.

www.cusip.com
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#2126184 - 04/13/17 04:48 PM Re: Loan Entity Identifier Truffle Royale
Truffle Royale Offline

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CUSIP is the ABA. So you'd be going through them to get your number.

question for anyone using something like CUSIP to get their LEI: Are these intermediary companies charging more than the $219 to get the LEI?

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#2126219 - 04/13/17 07:18 PM Re: Loan Entity Identifier Truffle Royale
Sinatra Fan Offline
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New Jersey
Nope. That's exactly what they billed us.
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#2126276 - 04/14/17 12:19 AM Re: Loan Entity Identifier Truffle Royale
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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You actually are authorizing CUSIP to order FOR you through the GMEI.

This box is checked:

I hereby grant explicit permission to secure a GMEI/LEI entity identifier on behalf of the issuer.

CUSIP is ordering on your behalf.
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HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2126277 - 04/14/17 12:23 AM Re: Loan Entity Identifier Truffle Royale
Kathleen O. Blanchard Offline

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When an entity such as CUSIP orders for you, it is an "assisted registration":

An LEI can be registered through a process known as Self-Registration. You must meet the following conditions to register an entity as the primary party:

You are currently an employee of the firm for which you are registering, or are currently an employee of the firm which has controlling interest over the entity you are registering.

You are authorized by your firm to register for an LEI.

An LEI can also be registered via Assisted Registration by a third party that is not associated with the entity being assigned an LEI, provided that the entity being assigned an LEI has given explicit permission for the third party to do so - more information can be found in our terms and conditions.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2126825 - 04/18/17 08:05 PM Re: Loan Entity Identifier Truffle Royale
Burgess Offline
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we are applying for our LEI right now. We are subchapter S and Business Enitity Type on the registration only gives us a choice between corporation and none of the above. I assume we are going with none of the above. agree?
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#2126826 - 04/18/17 08:06 PM Re: Loan Entity Identifier Truffle Royale
Burgess Offline
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our application is going through GMEI and I am about ready to hit send....a little nervous about the credit card payment going through the Netherlands. has anyone completed this application and had their credit card charged via the Netherlands? Netherlands will be a first for me?
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#2126828 - 04/18/17 08:09 PM Re: Loan Entity Identifier Truffle Royale
raitchjay Online
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OK
Yeah, the Netherlands sounds familiar......i paid it.
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#2127041 - 04/19/17 05:32 PM Re: Loan Entity Identifier Truffle Royale
David Dickinson Offline
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Central City, NE
Quote:
We are subchapter S and Business Enitity Type on the registration only gives us a choice between corporation and none of the above. I assume we are going with none of the above. agree?

A subchapter S is a corporation - an "S Corporation" (vs. C Corp and LLC). This might help:

Understanding corporation types

C corporation. A corporation is a separate legal entity set up under state law that protects owner (shareholder) assets from creditor claims. Incorporating your business automatically makes you a regular, or “C” corporation. A C corporation (or C corp) is a separate taxpayer, with income and expenses taxed to the corporation and not owners. If corporate profits are then distributed to owners as dividends, owners must pay personal income tax on the distribution, creating “double taxation” (profits are taxed first at the corporate level and again at the personal level as dividends). Many small businesses do not opt for C corporations because of this tax feature.

S corporation. Once you’ve incorporated, you can elect S corporation status by filing a form with the IRS and with your state, if applicable, so that profits, losses and other tax items pass through the corporation to you and are reported on your personal tax return (the S corporation does not pay tax).

Limited liability company (LLC). Another business type that is formed under state law and gives you personal liability protection is the LLC. Tax-wise, an LLC is similar to an S corporation (or S corp), with business income and expenses reported on your personal tax return. If you are the only owner of an LLC, you are viewed as a “disregarded” entity. This means you report the LLC’s income and expenses on Schedule C of Form 1040─the same schedule used by sole proprietors.
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#2127068 - 04/19/17 06:36 PM Re: Loan Entity Identifier David Dickinson
Burgess Offline
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Joined: Jan 2004
Posts: 1,620
Thanks David.

I think then, since the LEI application form only gives us "C corporation" and no "S Corporations" or even a generic "Corporation"

that we should list none of the above as our answer.
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#2127322 - 04/20/17 06:28 PM Re: Loan Entity Identifier Burgess
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,281
Why not ask the Help Desk? They are very responsive.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2127324 - 04/20/17 06:29 PM Re: Loan Entity Identifier Truffle Royale
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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And yes it is in the Netherlands but is a subsidiary of DTCC.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2128743 - 05/02/17 02:57 PM Re: Loan Entity Identifier Truffle Royale
QCL Offline
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NW IL
Just to clarify something for me.

I see that the Legal Entity Identifier is not part of the LAR data field codes for 2017 data, filed 1/1/2018. ( Filing instructions guide for HMDA data collected in 2017 Link)

And I do see that the Legal Entity Identifier is part of the Data field codes for the 2018 data file 1/1/2019. ( Filing instructions guide for HMDA data collected in 2018 Link)

But am I to understand that we still need the LEI in order to file on 1/1/2018?

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#2128760 - 05/02/17 03:44 PM Re: Loan Entity Identifier Truffle Royale
JWills, CRCM Offline
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The Mitten State
Where did you find that information? I thought we needed it for the 2018 data file.
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#2128765 - 05/02/17 03:56 PM Re: Loan Entity Identifier Truffle Royale
QCL Offline
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Posts: 6,259
NW IL
The phrase "Legal Entity Identifier" is not found within the first link - the Filing instructions guide for HMDA data collected in 2017 - which is why I wanted to clarify.

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#2128766 - 05/02/17 03:59 PM Re: Loan Entity Identifier Truffle Royale
CompliantOkie Offline
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OOOOOOklahoma
I believe it is only required for the 2018 data filed in 2019.

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#2128772 - 05/02/17 04:23 PM Re: Loan Entity Identifier Truffle Royale
#12 Offline
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Posts: 1,338
In my understanding, you don't need it to file on 1/1/18, but since it's part of the Universal Loan Identifier, you need it as of 1/1/18 to properly complete your 2018 data.
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#2128780 - 05/02/17 04:38 PM Re: Loan Entity Identifier Truffle Royale
QCL Offline
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QCL
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Posts: 6,259
NW IL
Thanks #12! I knew that I was missing something.

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#2128806 - 05/02/17 05:31 PM Re: Loan Entity Identifier Truffle Royale
David Dickinson Offline
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Central City, NE
That's correct. You need it with any data entries with action taken dates in 2018. These won't be filed until 3/1/19. Thus, I'm not recommending anyone get one until 2018. There's an annual fee too.

I wouldn't recommend waiting until Feb 2019, but you certainly don't need one now.
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#2128880 - 05/02/17 08:50 PM Re: Loan Entity Identifier Truffle Royale
CompliantOkie Offline
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OOOOOOklahoma
David, we were planning on getting one 4Q 2017. Should we push it to 1Q 2018?

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#2128885 - 05/02/17 09:17 PM Re: Loan Entity Identifier Truffle Royale
raitchjay Online
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OK
I wouldn't want to be closing any loans in January of 2018 that i would later have to go back and fix the ULI on, but that's just me.
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#2128887 - 05/02/17 09:24 PM Re: Loan Entity Identifier Truffle Royale
David Dickinson Offline
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Central City, NE
raitchjay brings up a good point. I don't have a strong opinion either way.
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