< Back to Articles

Attention HMDA Filers: You Need a LEI (Legal Entity Identifier). Top 3 Questions about Getting a LEI

Believe it or not the top 3 questions about getting a LEI are: 1. What is a LEI? 2. Where do I get a LEI? and 3. Is getting a LEI free? Hint: t isn't a flower necklace, you can't get one at the airport in Hawaii, and since the government requires it and a third party provides it you know it won't be free. The Legal Entity Identifier is the prefix to the new HMDA Universal Loan Identifier and must be obtained from an approved issuing organization.

What is a LEI

A Legal Entity Identifier ("LEI") is required as part of the HMDA Universal Loan Identifier ("ULI"). The LEI identifies the financial institution within the Universal Loan Identifier ("ULI") required by HMDA beginning in 2018. The LEI is 20 characters long and composed of a four character prefix identifying the issuing organization (LOU), a two character reserved separation, twelve characters identifying the financial institution and a two character checksum than insures it was typed properly.

The LEI precedes a 23 character loan identifier unique to the financial institution that will be followed by a two character checksum. Together these components form HMDA's 45 character ULI.

Worried your ULI won't be big enough to support your production? We do the math here.

Where can I get a LEI

Financial Institutions can check if they already have a LEI using this LEI search tool. Just type in your company name and click search. If your financial institution does not have a LEI one can be obtained from a LEI issuing organization also referred to as a local operating unit ("LOU"). The Global Legal Entity Identifier Foundation provides a list of issuing organizations, LOUs, here some are accredited, others are in the process.

When registering, if your company is owned by another organization, you will need to list parent organizations. Register the parent organizations first. Here is the information you will need to provide the LOU when you register for your LEI:

  • Your Legal Name
  • Other Entity Names
  • Your Legal Address
  • Your Headquarters Address
  • Other Addresses
  • Associated Entities
  • Your State of Formation (Legal Jurisdiction)
  • Your Business Register Entity ID (from the state of formation)
  • Your Legal Form (Corporation, LLC, etc.)
  • Your Entity Status (from the state of formation)

Is it free?

Of course not, and you will need to renew your LEI with the LOU annually.

Published on April 4th, 2017.

Shirk Law PLLC Copyright 2021