LEI Definitions: Closer to a Common Data Specification

In addition to writing, which is a pro-bono exercise compensated entirely by seeing my work in e-print and by emails reconnecting with old friends, I have a consulting practice which sometimes pays real money. One of my current projects involves helping set up the data controls for a migration from a nebulous set of existing applications and data sources to a new system.

Those of you who have done this type of work, you know that having a standard set of definitions for the incoming data files is essential. There is enough work to do once you have the data in validating it, looking for missing data and data that was once good but now is not (e.g. application owners who no longer work for the company). The last thing you need is to find out that what you thought "application" means and what the source system thinks "application" means are two entirely different things.

Hence, I was both encouraged and disappointed to hear that the Regulatory Oversight Committee (ROC) of the Global Legal Identifier System had recently developed and published a common data format for the Pre-LOUs (Local Operating Units). Encouraged because it happened, and disappointed that it hadn’t been done earlier.

Without getting into the details of the role of the Pre-LOUs (or why they are Pre’s and not actuals) it should be enough to know that these are the guys who issue the Legal Entity Identifers (LEIs) that everyone who is anyone is supposed to use. And they are supposed to do it consistently and without duplication:

The pre-LOU before issuing a pre-LEI should verify whether the requesting entity has already been recorded by another pre-LOU system and take the appropriate measures to ensure conformance with the principle of uniqueness and to avoid duplication of a pre-LEI. Where a pre-LEI already exists, the pre-LOU should refrain from issuing another pre-LEI…"
Principles to be observed by Pre-LOUs that wish to integrate into the Interim Global Legal Entity Identifier System (GLEIS)

As the ROC puts it in their document setting out the common data format, "The absence of a common data format across pre-LOUs adds complexity to the task of avoiding exclusivity violations … and difficulties for users uploading data from multiple pre-LOUs into their systems."

The ROC common data format is a modest first step – definitions for 21 basic data elements ranging from "legalEntityIndentifier=LEI" to operational statuses. It is to be followed by a more precise specification of the content, range and high-level technical design of LEI data records in support of the roll-out of the Global LEI System. Stay tuned...