354. To ensure a holistic treatment of the update to LEI, ESMA proposes to define also the procedures to be followed by the TRs when they receive a request to update an LEI. This is needed to set an appropriate framework for data collection, recordkeeping and data availability to authorities.

355. ESMA proposes that the below multistep process is followed by the TRs. This process complements the procedures established for counterparties.in section 4.4.2.2.

356. Moreover, a trade repository to which a request for update of an LEI is addressed should identify the derivatives outstanding at the time of the corporate restructuring event where the entity is reported with the old identifier in the field “Counterparty 1” or “Counterparty 2”, as informed in the relevant request and should replace the old identifier with the new LEI in the reports relating to all derivatives outstanding at the time of the event referred to and pertaining to that counterparty.

357. Furthermore, the trade repository should perform this procedure on the date of the corporate restructuring event or within 30 calendar days from receiving the request if such request was received later than 30 days prior to that event.

358. The TR should identify the relevant derivatives outstanding at the time of the corporate restructuring event where the entity is identified with the old identifier in any of the fields and replace that identifier with the new LEI.

359. A trade repository should carry out the following actions: