271. In the Consultation Paper, ESMA stressed the importance of the process to be applied by TRs and counterparties in case of changes in the LEIs due to mergers, acquisition or other corporate restructuring events already included in the TR Question 40.

272. Given the importance of this process and its impact on data quality, ESMA proposed to include in the RTS clarifications on: (i) time-bound elements both for the TRs and the counterparties, (ii) the ability to update transactions that are terminated at the time where the TR is performing the updates of the LEI, and (iii) process amongst TRs to ensure an update of all transactions where the LEI (impacted by the corporate event) appears as LEI of a counterparty or as the identifier of any other party that intervenes in the transaction.

273. The majority of respondents agreed with ESMA proposal to clarify these aspects and to include in the RTS the key elements of the process, especially with regards to timely bound elements as these are fundamental to ensure data quality.

274. A few respondents, while agreeing with ESMA's proposal, nevertheless suggested that the GLEIF should become the primary source for identifying and consuming changes to LEIs. However, ESMA noted that GLEIF cannot be used as source of information for updates under Q&A 40 procedure, as the exchange of information must take place ahead of the corporate event.