Is this something that must be purchased? Annual fee attached?

Do you mean legal entity identifier?

https://www.gmeiutility.org/

FAQ covers fees, etc.

https://www.gmeiutility.org/frequentlyAskedQuestions.jsp

I'm reading that as $219 to sign up.
Do we pay for the next year in advance when we sign up meaning 219 + 119?
When should we do this for 2018?

I would start no later than mid-2017 to avoid any delays in a year end rush.

My understanding is you pay annually. There is a small maintenance fee annually as well. It is all shown there.

Open all sections under Payments and you can see the info.

Kathleen - a couple of questions regarding the LEI
1. Are all HMDA reporting Financial Institutions required to have an assigned LEI for 2018 reporting and beyond?
2. If my institution is currently not required to report as we meet all tests (asset size, volume, etc) should we still apply for the LEI and have it in case we do have a year where we have to report?

Thank you.

Reviving this questions so it doesn't get lost.

1. Yes. It's a required entry on the LAR. Refer to §1003.4(a)(1)(i)(A).
2. I'd wait until you need it. There's a fee and you have to renew it annually. Why have one before you need it?

Thank you.

Just don't wait until the last minute and perhaps get caught in a backlog.

We are a unitary bank holding company. The parent (holding company) already has a LEI. Only the bank makes loans. Would the bank need to apply for a separate LEI, or can we use the Bancorp's?

It is my understanding that each reporting entity will need to have a unique LEI to report it's data. The final rule also mentions an "institution's" LEI - always in a singular context. I cannot find a specific requirement in the final rule that addresses your question, however.

Thanks, David. I couldn't find anything in the regulatory text, or the Official Interpretation, or in the Section-by-Section analysis, either.

I asked the GMEI Utility group about parent companies. The bank itself needs an LEI. If the parent company does not have one, the bank does not have to apply for one for the parent company as well, simply apply for the bank. But the bank needs its own.

Thanks, Kathleen. I was afraid that was going to be the answer.

HMDA 2018 just seems like a windfall for the GMEI Utility.

I agree. Everything I read implies the reporter needs to have a unique number.

HMDA 2018 just seems like a windfall for the GMEI Utility.
I agree.

Well, if we were going to have a consistent identifier (rather than the hodge podge respondent ID we have now) at least an existing system that quite a few US institutions already utilize was chosen, rather than a totally separate identifier only for HMDA.

So am I understanding that even if we have always been a HMDA reporting FI, I will still have to get a LEI for us?

Yes, you will need the LEI.

Thanks.

I am reading "covered transactions" need to include ULI included on applications and certain documents. If we are not a covered institution because we have not met the transaction thresholds in each of the prior two years, do we need to obtain the ULI just to have the # on our documents?

No.

@ Kake ... where are you finding that we have to include the ULI on application forms and other documents? I hope we do not have to do so. Thanks!

There is not a requirement to put the ULI on the application. It is an option on the updated URLA when released but I don't know if it will fit 45 characters.

Which organization did you all use to obtain the LEI? Is there any US companies that issue the LEI? The list I looked at appears to have only foreign companies.