Question
We are not yet clear about what is expected regarding 'issuer data' referring to the fields
A8 - Issuer Name
A31 - Issuer Code
A10 - Issuer Group
A32 - Issuer Group Code
A33 - Type of code
According to the explanation A8 should be filled with the name of the issuer. But ain't it right, that these expressions might be different from undertaking to undertaking or at least member state to member state? We see the same problem with A10 issuer group.
The explanation also says that for A31 and A32 the LEI or Pre-Lei should be reported. If none is available, this item should not be left empty. So how does EIOPA know (if the Issuer Name is different to other undertakings), who's the issuer of the item?
We are currently using the LEIs and Pre-LEIs for our derivates. Is it right, that we need to report the (Pre)-LEIs also for our bonds/funds/etc.?
EIOPA answer
In fact the cells referring to the “Name” will not be reported in an harmonised way. EIOPA is aware of that fact and that is precisely why the code and type of code is also requested. When the LEI code is available that problem will be solved, when it is not available NSA will use the information under “name” together with other sources of information to process the information received.
The LEI code should be used whenever it exists and it is referred to in the Instructions (LOGs).