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RegisterBench

Placeholder LEIs such as 9999999DUMMY99999999

The Central Bank of Ireland named a dummy LEI for a provider's ultimate parent as an example of a data quality check. What the EBA FAQ says about missing LEIs.

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What the sources say

The Central Bank of Ireland (CBI) wrote about the data quality feedback announced by the EBA:

"We have been given examples of some of the checks which will be performed" (Z-11)

The first example on the CBI page:

"An Invalid value reported for the Identification code of a TPP’s ultimate parent: 9999999DUMMY99999999" (Z-8)

The CBI page continues:

"Firms can reduce the likelihood of being asked to make a resubmission by checking that the content of the data makes sense before final submission." (Z-10)

The RoI reporting FAQ published by the EBA (question 40) covers a provider registered in a third country without an LEI. It says (spelling as in the source):

"the financial entity should populate the data filed with any relevant value to avoid the file being rejected as failing the referential integrity check" (Z-12)

"The use of such identifiers will be highlighted as a data quality issue, but the files will not be rejected" (Z-13)

What this means for your register

The two sources describe different situations. The EBA FAQ is about a third-country provider that has no LEI, where the field can be populated with any relevant value, which in practice could mean other identifiers available, and where such identifiers are highlighted as a data quality issue rather than rejected. The CBI example lists the code 9999999DUMMY99999999 and calls it an invalid value for the identification code of the ultimate parent. The quoted line does not give a reason why the value is invalid.

The string 9999999DUMMY99999999 has 20 characters and the shape of an LEI. By our own calculation its ISO 17442 check digits do not verify (the mod 97 result is 18, not 1). A check that looks only at length and characters would not notice it. A check on content would.

How to check before filing

  • List every identification code in the provider rows and in the ultimate parent column and look for repeated digits, words such as DUMMY or TEST, and codes shared by unrelated providers.
  • Verify the check digits of every LEI, not only its length.
  • Where a provider has no LEI, record which other identifier you used and why, so the choice can be explained if it comes back as a data quality finding.
  • Related rule page: v8855_m, rule summary: "If any other data column in a B_05.01 provider row is filled, the ultimate parent identification code (c0110) must be filled too."

Sources

This page is general information and is not legal advice.