Accreditation Documentation Checklist
Contents 2 AContactDetdils .........ciiiiiiiiiiniiiieninnenarentonssassssaeseesd BENtity Structure .........ciiitiiiiiiiiintiinernnennneeneennnnnnnaaa.lt C Organization Structure .. ..........ciiiiiiiiiiinnnnneeeessneneesas . 8 D Financial Data, Audits & General Governance . . . ................9 E Cost Recovery Requirements . .. ........c.coiiiiineeennnssenness..10 FLOU SEIviCes . ...ivviiitiinneenerenessnsssssssssssnssssnssnsssasssll G Required Website ltems . ............... .. ittt 15 HRecords Management .. ..........ciiiiiiiiiiiiiinrennnnnneneeas. 16 | Software Development .. ......... .ottt 17 J Networks & Infrastructure . . ........ ...ttt 17 KIT Security & Compliance . . ...ttt nnnnnnnnss.. 18 LData Quality Management .. .. ......c.iiiiiiiinnrtronnnnnneeeaas 19 Checklist Instructions Sections A, B, and C (Questions 1-3) must be completed and submitted as part of the Accreditation Plan. Sections D through L and the remaining guestions from Section C are to be completed and submitted after the Accreditation Plan has been agreed with GLEIF and the Master Agreement has been fully executed. Please note: This version of the Accreditation Checklist should be used by all Applicants and Candidates after 31 May 2021 for Accreditation and Annual Accreditation Verification when instructed. Any prior versions of the Accreditation Checklist will no longer be utilized nor accepted by GLEIF. This document is posted to the GLEIF website for public use and downloading. All questions as applicable consider and address both Level 1 and Level 2 data requirements. The Applicants/Candidates need to ensure this factor is incorporated into all responses. Please provide Informatlon felated to Parent/Owner andlor LEI Operations asnoted
GLEIF 2021/01
General Information for Accreditation Documentation Submission 1
Required Documentation to be Submitted with Checklist Responses F LOU Services Legal Name of Candidate LOU LOU Services Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. Issuenew LEls 11 Will you execute a formal contract either physically or Please provide a template and a brief narrative including electronically with a Legal Entity for every LEl issued? all points 1.2 Does your legal entity contract template include all requirements as defined in the Master Agreement Appendix 5? 1.3 Do you have astandard process for receiving payment from Please provide a brief narrative a legal entity for which an LEI was provided? 1.4 Upon receipt of an application do you have procedures Please provide a brief narrative on all points inplace for: 1.41 Verifying against an authoritative source the accuracy of the LE-RD provided by the LE? 1.4.2 Verifying existence and eligibility of the entity applying for the LEI? 1.4.3 Verifying that the individual signing the application is duly empowered? 1.4.4 Ensuring an up-to-date list of applicable accounting standards and authoritative sources is used for verifying that the reported relationship information exists? 1.4.5 Verifying the existence and eligibility of the relationship information reported? 1.4.6 Informing the Legal Entity that either its application shall require amendment, shall be refused, or the LEI has been issued and incorporated into the Global LEI repository? 1.4.7 Reporting the correct relationship information of the Legal Entity? 1.4.8 Uploading new LEI and LE-RD as well as relationship records to GLEIF? 1.4.9 Accepting without delay and processing applications for an LEI? GLEIF 2021|01
General Information for Accreditation Documentation Submission 12
Required Documentation to be Submitted with Checklist Responses F LOU Services Legal Name of Candidate LOU LOU Services Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 2. Enter Legal Entity Events 2.1 Do you have a formal process in place which includes: Please provide a template and a brief narrative including all points 211 Providing aninterface or mechanism for the Legal Entity to update LE-RD 21.2 Maintaining procedures for verifying the change is duly empowered to do so by: - Reverifying the authority of the requestor of the change? - Reconfirming the authorized person’s contact details including email address? - Reconfirming the requestor email address is not generic? 21.3 Checking,if an update to the relationship information is also required? 214 Verifying via an authoritative source the accuracy of the Legal Entity Event change? 215 Informing the Legal Entity of changed LE-RD and uploading the changed LE-RD to GLEIF? 3. Manage Challenges 31 Do you have aformal challenge process in place which includes: Please provide a template and a brief narrative including all points 311 Reviewing and responding to LEl and LE-RD challenges transmitted to the LOU by GLEIF? 31.2 Ensuring that the relationship information is also reviewed and changed, where applicable? 31.3 Informing the Legal Entity of validated challenges and uploading the changed LE-RD to GLEIF as applicable? 4. Transfer of LEls and LE-RD 4.1 Do youhave aprocess in place for a Legal Entity to request Please provide a template and a brief narrative including transfer of a LEI? all points 4.2 Does your process ensure that: 4.21 The defined and established transfer rules in the GLEIS are followed? 4.2.2 Procedures for verifying the individual requesting the LEI transfer is duly empowered to do so are in place? 4.2.3 The associated relationship information is transferred as well? 4.2.4 LE-RDis verified via an authoritative source? 4.2.5 Relationship information is correctly transferred as well? 4.2.6 The Legal Entity is informed (as applicable)? 4.2.7 The LElI and its changed LE-RD are uploaded to GLEIF? GLEIF 2021|01
General Information for Accreditation Documentation Submission 13
Required Documentation to be Submitted with Checklist Responses F LOU Services Legal Name of Candidate LOU LOU Services Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 5. Renewals of LEls 51 Are there procedures in place for: Please provide a template and a brief narrative including all points 511 Notifying Legal Entity of upcoming renewal requirements? 51.2 Providing aninterface or mechanism for the Legal Entity torenew? 5.1.3 Maintaining procedures for verifying the individual requesting the LEI renewal is duly empowered to do so? 514 Uploading the relationship information as well? 51.5 Verifying via an authoritative source the accuracy of the LE-RD? 51.6 Informing the Legal Entity about any missing or incorrect entries? 5.1.7 Receiving secure payments for the renewal? 51.8 Adjusting the LEl and relationship status as applicable to recognize renewal or non-renewal? 519 Informing the Legal Entity of renewal or non-renewal status? 5110 Uploading the changed LE-RD and the updated relationship information to GLEIF? 5.2 If you are planning to use multiple-year renewal contracts, Please provide a brief narrative including all points canyou please confirm that there are procedures in place for ensuring that the following will be performed on annual basis within the contract period: 5.21 Informing the Legal Entity about any missing orincorrect entries? 5.2.2 Adjusting the LEl and relationship status as applicable to recognize renewal or non-renewal 5.2.3 Informing the Legal Entity of renewal or non-renewal status? 5.2.4 Uploading the changed LE-RD and the updated relationship information to GLEIF? 6. Check for Duplicates 6.1 Are there procedures in place for checking against GLEIF's Check for Duplicates facility and process as defined? Please explain. 6.2 Are there procedures in place to avoid any types of duplicates in the system? Please explain. GLEIF 2021|01
General Information for Accreditation Documentation Submission 14
Required Documentation to be Submitted with Checklist Responses F LOU Services Legal Name of Candidate LOU LOU Services Type of Document Xref to Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 7. Code Lists 71 Are there procedures in place to ensure the implementation of the code lists updates within the defined timeframe? Please explain. 8. Code Lists 8.1 Are there procedures in place for checking against GLEIF's Data Governance Pre-Check API as defined? Please explain. 8.2 Are there procedures in place to avoid any data quality failures in the system? Please explain. 9. MetricData Collection 91 Do youregularly check your SLA performance in the SLA dashboard to ensure the timely remediation of any detected failure to prevent a service level breach and in case of a service level breach to immediately remediate it? 10. Third Party Resources /Registration Agents 10.1 Do you currently utilize third party services such as registration agents?
10.11 Does your organization have a formal vetting process for Please provide a description of how you develop, issue, evaluating the reliability of a third party service provider monitor and update procedures carried out by the third party or registration agents? If so, does it consider: service provider
10.2 Do you have a formal vetting process for evaluating the Please provide a brief narrative including all points reliability of a third party service provider or registration agents? If so, does it consider:
10.2.1 Financial stability
10.2.2 Market reputation
10.2.3 Abilities to meet LOU and GLEIF control requirements?
10.2.4 Evaluating the potential risks of utilizing the services provided
GLEIF 2021|01
General Information for Accreditation Documentation Submission 15
Required Documentation to be Submitted with Checklist Responses G Required Website Items Legal Name of Candidate LOU Required Website Items Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. After Accreditation, will your website: These items will be reviewed and documented during the live walk through of the LEI system. 11 Provide a transparent means for Legal Entities to submit and update registration information? 1.2 Provide a transparent means for Legal Entities to understand the process of requesting an LEI or LEI transfer? 1.3 Incorporate all terms and requirements of GLEIF's Terms of Use as defined in Appendix 9b of the Master Agreement? 1.4 Display your accreditation certificate on your LOU homepage? 1.5 Display the GLEIF logo? GLEIF 2021|01
General Information for Accreditation Documentation Submission 16
Required Documentation to be Submitted with Checklist Responses H Records Management Legal Name of Candidate LOU Records Management Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. Do you maintain a complete audit trail in compliance with Please provide a brief narrative and copies of all relevant policies 1SO 17442 data attributions and other Common Data File format elements (Level 1business card data and Level 2 relationship data) for all actions affecting the content or status of LEl records? 2. Isaparticular function responsible for all aspects of Please provide a brief narrative and copies of all relevant policies record retention as per your established internal policies? What is your testing process and periodicity? 3. Do you process paper records? If yes, are there specific Please provide a brief narrative and copies of all relevant policies retention policies regarding this? 4. Is periodic training provided to all relevant personnel Please provide a brief narrative and copies of all relevant policies (including employees, contractors and temporary staff) to make them aware of your Records Management procedures? 5. Do youcreate and maintain an internal list/index of relevant Please provide a brief narrative and copies of all relevant policies records and/or storage archives which includes information relating to Retention Periods and is it periodically updated? 6. Do you ensure indexing, scanning, retrieval, storage and Please provide a brief narrative and copies of all relevant policies destruction processes are documented, communicated, and tested at least annually? 7. Do your historical records include: 71 Al LEl data elements (Level 1business card data and Please provide a brief narrative and copies of all relevant policies Level 2 relationship data) for the current LEI and all of its associated changes? 711 If yes,dothe recordsinclude: Please provide a brief narrative and copies of all relevant policies - Effective date of any change(s) - The entity responsible for the change(s) - The reason for each change(s) - Who performed the change(s) - Who authorized the change(s) 7.2 ldentification of Data Sources for each issuance/change? Please provide a brief narrative and copies of all relevant policies 8. Do you ensure access to relevantrecords is restricted to only Please provide a brief narrati
ve and copies of all relevant policies those employees who are appropriately authorized and need access to perform their duties? 9. Do you ensure control procedures relating to the physical Please provide a brief narrative and copies of all relevant policies and environmental protection of relevant records, including archived datais in place and functioning properly? 10. Do you ensure relevant records are only destroyed in Please provide a brief narrative and copies of all relevant policies compliance with your procedures and any local or legal requirements? GLEIF 2021|01
General Information for Accreditation Documentation Submission 17
Required Documentation to be Submitted with Checklist Responses | Software Development | J Networks & Infrastructure Legal Name of Candidate LOU Software Development Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. Do youhave a document which describes the software Relevant process documents development tools and environment in place for the LEl operation? 2. Do youhave aformal process for developing and approving Relevant process documents new software? 3. Do youhave any outsourced software development Relevant process documents arrangements relating LE| operations? 4. Do youhave a process in place for identifying, Relevant process documents tracking and correcting software errors / bugs? 5. Doyouhave standard IT service management processes in place? Relevant process documents Please provide evidence that these are followed and maintained as needed. This would include a patching process and upgrade/ update policies and procedures. Networks & Infrastructure Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. Please provide anetwork diagram showing network Relevant process documents and technical diagrams entry points, firewalls, servers etc.. 2. Please describe the current server/hosting environment? Relevant process documents and technical diagrams Is it hosted, in-house, via a third party, etc.? Describe the use of any cloud-based resources such as Amazon Web Services or Microsoft Azure. 3. Do you perform any monitoring over the LEl-related Relevant process documents and technical diagrams ITinfrastructure? 4. Are there any redundancies built into the hosting platform Relevant process documents and technical diagrams and hardware? 5. Hasthere been any unscheduled network or system Relevant process documents and technical diagrams downtime in the past twelve months? 6. Do youhave acurrent disaster recovery and/or business Relevant process documents, results of last testing continuity plan in place? How often is it tested? cycle and summary of any incidents Has the plan been invoked during the past 3 operating years? 7. Do youhave structured backup policies and practices? Relevant process documents GLEIF 2021|01
General Information for Accreditation Documentation Submission 18
Required Documentation to be Submitted with Checklist Responses K IT Security & Compliance Legal Name of Candidate LOU Security & Compliance Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. Haveyou performed or engaged a third party to test Relevant process documents and most current reports system vulnerability, intrusion detection or perform penetration testing? Please list all vendors as applicable. 2. Do you maintain firewall(s)? Relevant process documents and technical diagrams; please describe its purpose and your monitoring procedures. 3. Isaccesstosource code and other critical resources Relevant process documents and technical diagrams (documents, contracts etc.) monitored and tracked? 4. Are there any users that are not subject to the standard Relevant process documents and list of exceptions security policies of the Company/Business Unit/Department? 5. Are there non-employees who have access to critical Relevant process documents and list of exceptions company information (source code, documentation etc.)? 6. Are terminated employees/contractors removed from Relevant process documents and technical diagrams access to LOU systems/resources in a timely manner? 7. Do youhave password policies for the networks and systems, Relevant process documents, technical diagrams including length and complexity, and any expiration policies? and most current reports 8. Do you have procedures in place to identify, Relevant process documents, technical diagrams report and remediate any security breaches? and most current reports 9. Do you have any physical access restrictions to Relevant process documents, technical diagrams critical company assets such as servers and data? and most current reports 10. Have you had any IT operational or security audits Relevant process documents and results of last testing cycle (i. e. SSAE 16, SAS70) performed in the past three years? 1. Have you had any LEl-related security breaches Relevant process documents, technical diagrams inthe past five years? and most current reports 12. Do you have your compliance activities in place to ensure Relevant process documents. Please specify which data privacy compliance with respect to all applicable Data Privacy Laws? laws you are enforcing and confirm that you are meeting the requirements documented in Appendix 11 of the Master Agreeme
nt. GLEIF 2021|01
General Information for Accreditation Documentation Submission 19
Required Documentation to be Submitted with Checklist Responses L Data Quality Management Legal Name of Candidate LOU Data Quality Management Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. General and Participation in Continuous Improvement 11 Does your organization have a governance framework that enables it to adhere to GLEIS standards? If yes, please explain how this governance framework is structured. 1.2 Does your organization have a continuous improvement process for data quality in place? If yes, please explain what the process stepsare. 1.3 Does your organization have a continuous improvement process for adapting to procedural changes as required for adjustments to ROC or GLEIF standard and operating principles? Please explain. 1.4 Does your organization have a defined implementation period expectation for different types of adjustments? Please explain. 2. DataValidation 21 Do you have an established data library that defines Please provide a brief narrative proper values for fields entered in a LEl request? 2.2 Do you prevent unlikely or incorrect data in submissions Please provide a brief narrative of LEl requests? 2.3 Do you maintain procedures for : 2.31 Verifying the LE-RD based on the Legal Entity Please provide a brief narrative jurisdiction, entity category and legal form? 2.3.2 Ensuring an up-to-date list of authoritative sources used Please provide a brief narrative including all points for verification is maintained, accessible and usable at all times with no restriction for all below services? a. Issue new LEI b. Enter Legal Entity Events c. Manage Challenges d. Transfer of LEls and LE-RD e. Renewals of LEIs (incl. multiple-year renewal contracts) 2.3.3 Do you have sufficient proficiency for understanding or Please list all languages interpreting authoritative sources? 2.3.4 Do you use other sources not listed in the GLEIF Registration Authorities list for verification/validation? If yes, please specify. 2.4 Do you have sufficient language proficiency in the jurisdictions you are applying for understanding and interpreting the following? If yes, please list all languages. 2.41 The information you receive fromthe legal entity? 2.4.2 Theinformation provided in the corresponding authoritative source for validation? GLEIF 2021|01
General Information for Accreditation Documentation Submission 20
Required Documentation to be Submitted with Checklist Responses L Data Quality Management Legal Name of Candidate LOU Data Quality Management Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 2.5 Do you have validation procedures in place for Please provide a brief narrative including all points 2.51 Verifying that a Legal Entity is eligible for an LEI code? 2.5.2 Provision of corresponding language tags for the set of specified fields? 2.5.3 Incorporating Transliteration data for all below services? a. Issue new LEI b. Enter Legal Entity Events c. Manage Challenges d. Transfer of LEls and LE-RD e. Renewals of LEIs (incl. multiple-year renewal contracts) 2.5.4 Ensuring that LEls are only issued when validation process is successfully completed? 2.5.5 Verifying the LEI Record Set is compliant with the Common Data File (CDF) format (as published per www.gleif.org) 2.5.6 Ensuring a LEI complies with GLEIF Operational and Technical Standards (Data Quality Rule Setting) during all below services: a. Issue new LEI b. Enter Legal Entity Events c. Manage Challenges d. Transfer of LEls and LE-RD e. Renewals of LEIs (incl. multiple-year renewal contracts) 2.5.7 Researching the content of the challenge and verifying the challenge via an authoritative data source? Please explain. 2.6 Do you comply with ISO 17442? Please provide a brief narrative. GLEIF 2021|01
General Information for Accreditation Documentation Submission 3
Required Documentation to be Submitted with Accreditation Plan A Contact Details Legal Name of Applicant LOU | Note: This name must match your LEIl reference Data VAT No. if applicable URL of Applicant LOU Submission Date (YYYY-MM-DD) Parent/Grandparent/Owner/Governing Organization if applicable Accreditation Plan Checklist LEI of Parent/Grandparent/Governing Organization if applicable First Submission Revised Submission Internal Project Manager Authorized Representative Name Name Title Title Email Email Phone Phone Key Contact Operations Key Contact Finance Name Name Title Title Email Email Phone Phone Please ensure you have: Yes No In Progress ¢ Provided your LEl below ¢ Provided a Notarized Copy of the Authorized Representative’s Signature In submitting this document, | confirm that, to the best of my knowledge, my organization is in compliance with or is able to become compliant with the requirements of GLEIF reflected in the Master Agreement and its appendices, Accreditation Manual and Checklist and Service Level Agreement as of the date of this document unless otherwise noted. Authorizing Representative Signature* Date (YYYY-MM-DD) E-Signature Name Title Email LEI (20 Alphanumeric Characters) Phone
- Please note: the Authorized Representative may sign this form physically or electronically
GLEIF 2021/01
General Information for Accreditation Documentation Submission 21
Required Documentation to be Submitted with Checklist Responses L Data Quality Management Legal Name of Candidate LOU Data Quality Management Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 3. Check for Duplicates Please provide a brief narrative including all points Do you have procedures in place for handling each of the following 31 Checking that the LEI code does not exist already in the Global LEI Index? 3.2 Checking, that the legal entity does not have an assigned LEI code already? 3.3 Checking that no duplicate relationships exists? 3.4 Identifying Exclusivity Violations by using automated routines? 3.5 Checking the received feedback from GLEIF's Check for Duplicates facility? 3.6 Ensuring that all newly issued LEls are processed by GLEIF's Check for Duplicates facility? 4. Data Governance 4.1 Have you integrated the Data Governance Pre-Check API Please provide a brief narrative. into your processes? If yes, please describe briefly. 4.2 Do you process the received feedback from GLEIF's Data Governance Pre-Check APl and take actions based on this feedback? Please explain briefly. 4.3 Do you ensure that all newly issued and updated LEls are processed by GLEIF’'s Data Governance API to fulfil the Completeness Service Level Target? Please explain briefly. 5. Uploading of LEIs and LE-RD Please provide a brief narrative including all points Do you have procedures in place to ensure: and your relevant procedures documentation. 51 Timely response to any GLEIF communication concerning doubts, inconsistencies, or data quality issues of the uploaded data? 5.2 Uploading LEl records at least daily? 5.3 Confirmation to GLEIF via the GLEIF interface/ If yes, please explain the process control with respect communications protocol indicating a daily “live signal” to monitoring this condition. given no LEl activity occurs? GLEIF 2021|01
G LE I F Enabling global identity Protecting digital trust Global Legal Entity Identifier Foundation (GLEIF) St. Alban-Vorstadt 12, PO Box 4002 Basel Switzerland accreditation@gleif.org gleif.org Chairman of the Board: Teresa Glasser Chief Executive Officer: Stephan Wolf © 2022 All rights reserved GLEIF 2021/01
General Information for Accreditation Documentation Submission 4
Required Documentation to be Submitted with Accreditation Plan B Entity Structure Legal Name of Applicant LOU Organization Structure Parent/Governing Organization Applicant LOU Government Government Private - For Profit Private - For Profit Private - NonProfit Private - NonProfit Public-Listed Public-Listed Public-Non-Listed Public-Non-Listed Not Applicable - there is no parent/owner Other Other Accounting Framework Check as many as applicable Internal Controls Framework Check as many as applicable US GAAP COSO IFRS COBIT Transitioning to IFRS 1SO* Other - Please specify* Other - Please specify** Unknown/Not Applicable Unknown/Not Applicable +Comments (if any) * Please note the applicable standard and provide the certificate if you have been certified *Comments (if any) FISCAL YEAR (Please provide your business calendar) Payment Currency Please choose one usD - EUR Date (YYYY-MM-DD) Date (YYYY-MM-DD) CHF (@Pisssaprovidalrformationiralotad toParstiONanandlos LE| Opatotions ssnated ) GLEIF 2021|01
General Information for Accreditation Documentation Submission 5
Required Documentation to be Submitted with Accreditation Plan B Entity Structure Legal Name of Applicant LOU
Jurisdiction - Self-Registration
Please complete the Registry Inventory Spreadsheet Form and include it in your Accreditation Plan submission. The form is on our website.
Statement of Beneficial Ownership
Please list all Entities which have > 20 % Entity LEI# %
ownership stake in your organization
Potential Taxation Requirements
Please detail your taxation strategy as it relates to your operations and LOU services
GLEIF 2021|01
General Information for Accreditation Documentation Submission 6
Required Documentation to be Submitted with Accreditation Plan B Entity Structure Legal Name of Applicant LOU External Audit Firm (if applicable) Comments (if any) First Name Yes No Not Applicable
Are annual financial statements issued?
Parent Level
LOU Level Is an annual management letter/report issued which relate to LEl services? Are your financial statements public record?
Parent Level?
LOU Level? Governmental/Regulatory Auditors (if applicable) Comments (if any) Organization
Yes No Not Applicable
Are annual financial statements issued?
Parent Level
LOU Level Are periodic management letters/reportsissued which could relate to LEI services?
Parent Level
LOU Level Are these reports public record?
GLEIF 2021|01
General Information for Accreditation Documentation Submission 7
Required Documentation to be Submitted with Accreditation Plan B Entity Structure Internal Audit Group (if applicable) Comments (if any) Department Yes No Not Applicable Are financial/operational/IT scope audits performed? Parent Level LOU Level Are periodic management letters/reportsissued which could relate to LEI services? Are these reports public record? External Consultants (if applicable) Comments (if any) Yes No Not Applicable Have you engaged a third party to evaluate your business and/or IT Parent Lou Both operations/controls? Are any of these reports SSAE16 SOC Type 1 or equivalent? Parent Lou Both Are any of these reports SSAE16 SOC Type 2 or equivalent? Parent Lou Both Are any of these reports ISAE3402 or equivalent? Parent Lou Both Are any of these reports public record? Parent Lou Both Please specify the provider of service(s): Comments (if any) Please note: For any third party reports submitted for Accreditation consideration, please indicate which specific LEl operations and questionnaire sections/ items it addresses. In these cases, the LOU does not need to provide additional supporting documentation unless requested by GLEIF. GLEIF 2021|01
General Information for Accreditation Documentation Submission 8
Required Documentation to be Submitted with Accreditation Plan C Organization Structure Legal Name of Applicant LOU Govern- Private - Private- Public- Public Organization Structure ment For Profit NonProfit Listed Non-Listed Type of Document Applicability Applicant LOU Response Included Not Not Not included included applicable cannot be provided due to con- fidentiality 1. Prior Year Financial Statements (Parent/Owner) N Y Y Y Y 2. Auditor/Regulator Letter(s)/Report(s) Y N N Y Y (Parent/Owner & LEI Ops) 3. Most Recent Annual Report N Y Y Y Y 4. Current Organization Chart for all LElI Operations and Y Y Y Y Y complete list of all relevant third party service providers. 5. Relevant Operational Procedures (LEI Ops only) Y Y Y Y Y 6. Relevant Technical Procedures (LEI Ops only) Y Y Y Y Y 7. Relevant Compliance Procedures (LEI Ops only) Y Y Y Y Y 8. Records Retention Policy (Parent/Owner & LEI Ops) Y Y Y Y Y 9. Relevant third party and Vendor Agreements (LEI Ops only) Y Y Y Y Y Comments Please note: Documents 1-3 should be provided as part of the Accreditation Plan submission. The remaining examples will support your responses in other sections of the Checklist and you should gather current versions as applicable and provide to GLEIF after the signing of the Master Agreement. GLEIF 2021/01
General Information for Accreditation Documentation Submission 9
Required Information to be Submitted with Checklist Responses D Financial Dataq, Audits & General Governance Legal Name of Candidate LOU Financial Data, Audits & General Governance Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. General Questions - Going Concern - Parent and LOU 11 Hasanindependent audit of your financial statements Audited financial statements (income statement, balance sheet, been performed for your last completed fiscal year? cash flows statement) for prior year If your organization does not have audited statements, please provide your prior and current financials as maintained. Please explain how these statements are validated and reported. 1.2 Has your audit firm/government regulatory agencies issued any Final Management Letters with management responses management letters relating to LEI operations over the past as applicable. three years? - This would include commentary relating to internal controls, accounting controls and methods of procedures. 1.3 Do you have aninternal audit function? 1.3.1 Have they performed any audits within your organization Relevant issued internal audit reports which relate to LEI relating to LEI operations? operations in the past 2 years Please include management responses. 1.4 Have you been subject to any regulatory audits/reviews Relevant comment letters, audit reports (qualified and inyour current year’s operations? unqualified opinions) and management responses as applicable 1.5 Do you have aformal LEI Operations Budget for this year Please provide budgets as per GLEIF instructions and and next year's operations? explain financial assumptions, volume estimations, operating budget, expenses etc. - soft copies should be submitted wherever possible. 2. General Questions - Going Concern - Parent and LOU 21 Are third party services (e. g. augmented staff, cloud services, Summary of vendor contracts and detailed description of data centers) utilized in order to provide LEl services? services provided; copies of contracts may be requested 2.2 Doyou have intellectual property and/or proprietary methods/ Provide a description of the asset and its use with respect systems which are employed in the delivery of LEI services? to LEl services 2.3 Are you currently involved with any litigation matters Provide a summary of all relevant litigation, arbitration, whic
h could effect LEI services? claims and proceedings 2.4 Are you subject to regulatory compliance Please list all relevant governmental regulatory agencies requirementswhich could effect LEI operations? and the applicable regulations with respect of LEI activities GLEIF 2021|01
General Information for Accreditation Documentation Submission 10
Required Documentation to be Submitted with Checklist Responses E Cost Recovery Requirements Legal Name of Candidate LOU Cost Recovery Requirements Type of Document Xrefto Docs Provided Yes No N/A Additional Documentation Requested Please cite document Please check one and page # 1. Do youclearly understand the technical requirements Please summarize any actual or contemplated changes of the Cost Recovery Principle? to the GLEIF-approved Plan since the date of Master Agreement signing. 2. Do you confirmthat the LOU business operations will comply Please summarize any actual or contemplated changes with the Cost Recovery Principle at and after accreditation? to the GLEIF-approved Plan since the date of Master Agreement signing. 3. Do you confirmthat the LOU business operations will comply Please summarize any actual or contemplated changes with the Cost Recovery Principle at and after to the GLEIF-approved Plan since the date of Master Agreement signing. 4. Do you clearly understand the requirements of the annual Please summarize any actual or contemplated changes verification process and the independent cost recovery audit? to the GLEIF-approved Plan since the date of Master Agreement signing. 5. Please confirm that your budget information as submitted conforms to the following definitions: Direct Cost: Specifially allocable to a particular business that can be accurately and clearly traced, with little effort, to said business activity, including intercompany transfer fees based on “arm’s lengths” terms and fees paid to third party service providers assisting the performance of Services agreed in the Service Level Agreement (Appendix 06). Only the services mentioned in the above definition should be considered to be the cost objects for the purpose of calculating direct costs. Types of Direct Cost: Dedicated LOU Personnel costs: e.g. salary overtime, recruitment costs, Travel, Training Dedicated LOU Resources: e.g. IT hardware/software/ supplies, telephone/internet, stationary & postage. Dedicated LOU Support: e.g. Marketing, monitoring, legal, audit costs, GLEIF fees. A Candidate LOU must submit three-years operating budget information Please note the following: in Excel format for Cost Recovery review by GLEIF. A specific definition of each cost category and its relevance to LEl operations must be included. @ Do not include any indirect/overhead costs as part of LEI direct costs. This i
ncludes costs such as general administrative functions Please provide detailed (line by line) disclosure of DIRECT COSTS and management time. The overarching 100 % uplift factoris (defined above) that can be specifically allocated to the Services applied to compensation for these costs. outlined in Section F of this document. @ For costsrelating to intercompany transfer fees and fees paid It needs to be clearly demonstrated that these costs are direct to third party service providers, please provide detailed cost costs as defined. information by service and provider separately from the Direct Cost data. Do not include these costs in the LEI direct costs data. @ Alldata provided is subject to inquiry and/or audit at GLEIF’s discretion. GLEIF 2021|01