Maintaining the Legal Entity Identifier (LEI): Should Partially-exempt HMDA Filers Renew?

The passing into law of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) provided institutions with a partial exemption of some data fields under HMDA. One of the fields in the exemption is the Universal Loan Identifier (ULI) and allows institutions to report a Non-Universal Loan Identifier (NULI). The difference between the two is that the ULI is comprised of the Bank’s LEI plus a unique loan number and check digit, whereas the NULI only requires a unique loan number. Many institutions have the misconception that their LEI does not need to be renewed and that it is no longer needed. However, this is not the case.

The LEI is the number that replaced the Respondent ID number and it identifies the reporting HMDA LAR filer.

When should I renew my LEI?

The LEI can be renewed up to 45 days prior to the expiration date. Not sure if your LEI has been renewed? Check out the Global LEI Index site at https://www.gleif.org/en. If your LEI has not been renewed, you will receive a “LAPSED” status. If you are afraid you will lose out by renewing early, have no fear. Whatever time you have left before the expiration will be added to the next expiration date once the renewal process has been approved and completed. If the LEI has already expired (lapsed), the new LEI will expire 12 months from the date the issuing agent completes the request for the renewal.

What is needed to renew the LEI?

Depending on who the issuing agency is, they may request your registration entity ID number, the legal name of the institution, the registered address, headquarters address, registration authority identification, entity type, and legal form. If you are unsure what information you reported on the initial data, this information can be found when you pull up your LEI information on the issuing agency’s website.

Where do I renew the LEI?

The LEI should be renewed with the organization from which you originally obtained the LEI. No other organization will be able to renew the LEI.

Is there a fee for renewing the LEI?

Yes, there is an annual fee for renewing the LEI and it is around $100. This fee amount is approximate because each agency may charge a different fee; this means the fee could be a little lower or a little higher.

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