Board of Governors of the Federal Reserve System

January 2011

Creating a Linchpin for Financial Data: Toward a Universal Legal Entity Identifier

John A. Bottega and Linda F. Powell

Abstract:

The financial industry, like many others, is powered by information and data. A number of government agencies, quasi-government agencies, and private companies collect, process, use, and distribute information about a variety of players in the financial world. While the subjects of the data (balance sheet items or counterparty information, for example) may vary dramatically by agency and use, they all describe a particular financial institution or legal entity. Yet a standard way to uniquely identify one financial entity from another does not currently exist. A Social Security number distinguishes one John Smith from another John Smith, but at present no single identifier distinguishes one First National Bank from another. Several private companies have developed proprietary identifiers created for their own purposes but none of those identifiers are industry-wide, universal, or strictly focused on identifying a specific institution.

A diverse group of analysts from the Board of Governors of the Federal Reserve System, Federal Reserve Bank of New York, Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Financial Industry Regulatory Authority (FINRA), Securities and Exchange Commission (SEC), and Treasury have developed guidelines detailing the best way the industry might create, develop, and maintain such a crucial identifier. The paper summarizes the current environment of entity identification and the problems that are currently encountered in both the private and public sectors by the lack of an industry-wide identifier. The paper identifies the key components that should be incorporated into the LEI such as uniqueness, persistence, and public availability. The paper identifies possible alternative approaches to solving the LEI problem and supports a collaborative public and private sector approach. The paper also considers the need for an international solution, as financial markets grow ever more interconnected across the globe.

Keywords: Legal entity identification, reference data, metadata

PDF: Full Paper