Loan Entity Identifier

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.

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.

Totally agree!

Thank you.

Cusip Global Services provides LEIs.

www.cusip.com

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?

Nope. That's exactly what they billed us.

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.

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.

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?

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?

Yeah, the Netherlands sounds familiar......i paid it.

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.

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.

Why not ask the Help Desk? They are very responsive.

And yes it is in the Netherlands but is a subsidiary of DTCC.

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?

Where did you find that information? I thought we needed it for the 2018 data file.

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.

I believe it is only required for the 2018 data filed in 2019.

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.

Thanks #12! I knew that I was missing something.

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.

David, we were planning on getting one 4Q 2017. Should we push it to 1Q 2018?

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.

raitchjay brings up a good point. I don't have a strong opinion either way.

Yeah, I would think you need it so that all entries beginning with action dates of 1-1-18 have the complete identifier.

To be honest, I went ahead and got ours just so I could check off one item on that horrible HMDA list.

I wouldn't put it off. Our LOS will generate the ULI when the loan is created - we wont have to worry about creating a ULI afterwards. We got our LEI back in Q1 of this year.. one less thing to worry about towards the end of the year.

"Our LOS will generate the ULI when the loan is created - we wont have to worry about creating a ULI afterwards."

That is one reason to get your LEI. To be able to test your LOS to insure they are correctly calculating the ULI. Also to avoid any potential last minute rush of thousands of lenders applying for the LEI.

Isn't it just a matter of a day or two between applying for the ULI and getting it? (granted if you wait till everybody else does, just like HMDA filing on 3/1, turn-around will slow down)
Also, does the fee run from the date of application or is it a 1/1 through 12/31 fee?

According to GMEI, it is a 3-day turnaround from application to receipt.

I agree with Dan that it makes sense to get the LEI now so you can test your LOS.

I randomly selected Bloomberg from the list on GLEIF, and their prices are $75 for a new registration and $50 for annual renewal. Does anyone know why they would be so much cheaper than going through the GMEI Utility? I thought the $219 and $100 were standards for U.S. registrations.

We tried to register through GMEI Utility and our credit card company rejected the transaction and shut down our card since it was in the Netherlands. Opted to use Bloomberg instead.

I got ours last week. I submitted my request on Monday, May 1, and on May 3, I received an email from the GMEI Utility that they had issued our number. I have not heard of Bloomberg. I would have thought the fees would be the same.

Susan R, was their anything different about Bloomberg's registration or number? Since I thought they were all the same price, I was very surprised that they were so much cheaper. It made me a little skeptical about the whole thing.

Am I understanding correctly that the only number we pay for is the LEI #? Our software will calculate the ULI# (which will be added to the LEI#)? and what about the "check digit"...does that cost $$ and where do we get that?

Yes, the only number you pay for is the LEI#. We got ours in two days from GMEI. Hopefully the new CFPB tool will be helpful in calculations that check digit based on the ULI #. Not real sure about that one, but I am sure about what you pay for. Also, there is an annual fee for the LEI number and I think it is $100.00.

It appears that now MERS is entering the fray as a provider of the LEI.

So of course, I'm being asked what difference it makes where we get the number from and, more to the point, what do the various companies charge.

Would appreciate people weighing in with names and numbers I can share with my bank.
Thank you.

Clarification: By 'numbers' I mean how much did it cost wherever you got your number.

We randomly selected Bloomberg from the list also, and the fee was $75. They issued our LEI number within about a day.

Is MERS going to issue our LEIs for free? And do we know WHEN they will issue them? I am ready to begin testing, but management is wanting to use MERS because their understanding is that it will be free.

MERS is offering three webinars to address their LEI offering but unfortunately, all three are full and closed.
The webinar had a $10 fee.
The site does note that recordings will be available but doesn't state whether they will be free or not.
I have reached out to them asking for another session or at the very least, explanation of cost for listening to recording.

I think they are dreaming. While they might be facilitating obtaining an LEI, I see nothing that says they are going to do it for free.

Yeah that's what I'm afraid of. So we might as well get it over with now!

Just got this from Amy Moses at MERS:

That is definitely different than issuing LEIs for free.

I don't know anything about what MERS will charge or not, Randy.
I also have no idea what led Banker K's management to think MERS would be getting the LEIs for free. Maybe they got a communication I didn't. That's why I want to attend (or now listen) to one of these webinars.

MERS sent out an email on 5/15/17 with subject "MERSCORP Holdings to Provide LEI Registrations and Renewals to U.S. Mortgage Industry". It was forwarded to me from another Banker here. When I asked about purchasing our LEI, management thought the email meant that MERS would provide its members free registration.
It was a confusing email so I sent my Q to MERS.
They replied that their "service" should go live on July 1st for members, and this is for aid in the PROCESS to apply for/renew/update an LEI. They are streamlining it to pre-populate fields for their members that they already maintain on us. They said we still have to pay the new LEI cost of $119 (or renew for $99). They also mentioned those webinar. Then they gave me a table of the fields of information we would have to have to apply for our LEI.

So I'm guessing (hoping) management will just give me a credit card and the okay to go ahead and get signed up ourselves and not have to add yet another company/party to this whole mess.

There is no requirement to use an issuer particular to any country. This link provides a list of the accredited issuers: https://www.gleif.org/en/about-lei/how-to-get-an-lei-find-lei-issuing-organizations

GMEI Utility seems to be recognized as the most used provider for US institutions. https://www.gmeiutility.org

Sorry, posted that before I saw page 2 and 3 of the thread, but still think the information is useful. Basically, if an issuer is accredited, it would likely make sense to go through the list and see who has the lower prices, if there are differences.

Has anyone used Bloomberg for obtaining their LEI. From what I can tell Bloomberg seems to be cheaper unless I am looking at the wrong information. Thanks.

I used Bloomberg. Simple process, and it only cost $75.

Unless you put a value on your time! Because of a big push in Europe to register for a securities law, the price going through GMEI is now $100.