Connect the Dots with High Quality LEI Data: GLEIF Introduces New Quality Criteria and Performance Checks to Further Optimize Data Quality in the Global LEI System
GLEIF continues to enhance its data quality management program, empowering market participants to benefit from the wealth of information available within the LEI population
Author: Stephan Wolf
Estimated Reading Time: 12 minutes
This blog describes the most recent enhancements to the data quality management program implemented by the Global Legal Entity Identifier Foundation (GLEIF). With the monthly data quality reports published in September 2018, GLEIF introduced new data quality criteria and additional data quality checks. This allows for a more detailed performance analysis and further increases transparency on the data quality achieved in the Global Legal Entity Identifier (LEI) System.
In the Global LEI System, GLEIF is responsible for monitoring and ensuring the high quality of LEI data. In cooperation with our partners, the LEI issuing organizations, we focus on optimizing the quality, reliability and usability of the LEI data. This empowers market participants to benefit from the wealth of information available within the LEI population. Each LEI contains information about an entity’s ownership structure, answering the questions of 'who is who’ and ‘who owns whom’. GLEIF makes the entire LEI data pool available via the Global LEI Index. It contains historical and current LEI records including related reference data in one authoritative, central repository and is accessible to LEI data users free of charge. The Global LEI Index is the only global online source that provides open, standardized and high quality legal entity reference data.
The links to the monthly data quality reports published by GLEIF and further background material are included in the ‘related links’ below.
New data quality criteria introduced to measure the level of data quality in the Global LEI System
A key feature that distinguishes the LEI from proprietary identifiers, is that GLEIF provides complete transparency regarding the level of data quality achieved in the Global LEI System. We do this by making available the following monthly reports:
The Global LEI Data Quality Reports demonstrate the overall level of data quality achieved in the Global LEI System.
The LEI Issuer Data Quality Reports analyze the level of data quality achieved by the individual LEI issuing organizations (also referenced as ‘Local Operating Units’).
In close dialog with the LEI Regulatory Oversight Committee and the LEI issuing organizations, GLEIF has defined a set of measurable quality criteria to clarify the concept of data quality relative to the LEI population. For this, standards developed by the International Organization for Standardization (ISO) have been used. These include criteria such as the completeness, comprehensiveness and integrity of the LEI data records. (For the complete list of data quality criteria, refer to the GLEIF website page ‘GLEIF Data Quality Management Program – Questions and Answers’ included in the ‘related links’ below.) By instituting a set of defined quality criteria, GLEIF has established a transparent and objective benchmark to assess the level of data quality within the Global LEI System.
With its data quality reports published in September 2018, GLEIF has introduced checks assigned to three new data quality criteria:
Accessibility: Data items that are easily obtainable and legal to access with strong protections and controls built into the process.
Provenance: History or pedigree of a property value.
Representation: The characteristic of data quality that addresses the format, pattern, legibility, and usefulness of data for its intended use.
These new data quality criteria contribute to assessing whether the LEI data records are consistent and plausible.
New data quality checks further increase the usability and reliability of the LEI reference data
To recap: The process of maintaining LEI data quality starts with the registering entity. Through self-registration, the registering entity must supply accurate LEI reference data. The LEI issuing organization must then verify the LEI reference data with the local authoritative source – a national Business Register, for example – and issue an LEI compliant with the LEI standard. Once a legal entity has obtained an LEI, it will be published together with the related legal entity reference data by the Local Operating Unit that has issued the LEI. Each Local Operating Unit publishes updated files daily including LEIs it has issued and related reference data.
Using software developed by GLEIF, the LEI data records made available by the LEI issuing organizations are checked daily against the defined quality criteria. GLEIF sends a daily report detailing the results of the performance assessment to the LEI issuing organizations. With the data quality reports published in September 2018, GLEIF introduced several new data quality checks. In total, GLEIF performs 75 quality checks to assess the overall quality of the LEI data pool.
The new quality checks examine, specifically:
Use of the GLEIF Registration Authorities List: As mentioned above, an LEI issuing organization must verify the LEI reference data supplied by a registrant with the local authoritative source prior to issuing an LEI. GLEIF publishes the ‘Registration Authorities List’. It contains more than 650 business registers and other relevant registration authority sources and assigns a unique code to each register on the list. The LEI issuing organizations reference this code in their LEI issuance processes and publish it with the LEI record. The Registration Authorities List standardizes the cross reference provided by the legal entity to its local authoritative source for the first time. With this list GLEIF enables users of the LEI data to more easily link the LEI to other data sources.
GLEIF has introduced various new data quality checks to verify whether an LEI record states the correct code assigned to the relevant authoritative source on the Registration Authorities List. In the event that an LEI record fails these checks, the responsible LEI issuer must update the record to provide the correct code. This ensures that data users can take full advantage of the standardized information provided with the Registration Authorities List – and, subsequently, with an LEI record – when researching information on a specific entity and linking its LEI to other sources, e.g. a business register.
By scrutinizing the correct application of the Registration Authorities List code, GLEIF also determines whether an LEI issuer can credibly indicate that an LEI record is fully corroborated. If an LEI record includes the information that it is a ‘Fully Corroborated LEI’, it means that based on the validation procedures in use by the LEI issuer, there is sufficient information contained in authoritative public sources (identified with a code from the Registration Authorities List) to corroborate the information that the legal entity has supplied. GLEIF now performs specific checks to investigate the relation between the data field in an LEI record that indicates the Registration Authorities List code and the field that indicates if a record is fully corroborated. If an LEI record is declared to be fully corroborated yet the Registration Authorities List code is either missing or erroneous, the associated data quality checks fail and the LEI issuer must provide further information. With related new quality checks, GLEIF further increases the reliability of the information included within an LEI record.
Use of the ISO 20275 – Entity Legal Form Code List: GLEIF publishes the ‘Entity Legal Forms (ELF) Code List’. The first iteration, released in November 2017, lists more than 1,600 entity legal forms across more than 50 jurisdictions. Examples of entity legal forms include: Limited liability partnership (LLP), Gesellschaft mit beschränkter Haftung (GmbH) or Société Anonyme (SA). The ELF Code List assigns a unique code to each entity legal form. The ELF Code List is based on the ISO standard 20275 ‘Financial Services – Entity Legal Forms (ELF)’.
With the new data quality checks, GLEIF examines whether an LEI record states the correct code representing an entity’s legal form in accordance with the ELF Code List. The LEI record will fail this test if there is a mismatch between the legal form associated with an ELF code and the legal form stated with an entity’s name. Integrating ELF codes into the standardized set of reference data on a legal entity available within the Global LEI Index, further enhances the business card information included in each LEI record. The richer data provides an improved user experience, because it helps to categorize legal entities and therefore allows for more insight into the global market place. The new related quality check therefore, ensures that data users can take full advantage of the ELF code as part of the business card information included with an LEI record.
Correct information on ownership structure (‘who owns whom’): The business card information available with the LEI reference data, e.g. the official name of a legal entity and its registered address, is referred to as ‘Level 1’ data. It provides the answer to the question of ‘who is who’. The LEI data pool also includes ‘Level 2’ data to answer the question of ‘who owns whom’. This data allows the identification of the direct and ultimate parents of a legal entity and vice versa, in order that the entities owned by individual companies can be researched.
Based on new data quality checks, GLEIF verifies whether the ownership information related to an LEI registrant is recorded in line with the applicable policy defined by the LEI Regulatory Oversight Committee. In addition, GLEIF now investigates the plausibility of relationship information relevant to entities classified as branches that have obtained an LEI. These new checks further improve the reliability of the LEI data.
Updated documentation provides detailed information on the methodology applied to assess data quality in the Global LEI System
The document ‘Data Quality Rule Setting’ identifies the checks performed against the quality criteria. The results of the quality assessment reflected within the monthly GLEIF data quality reports are based on the results of these checks. In September 2018, GLEIF published the updated version 2.1 of the document which details the new data quality checks described above.
In addition, GLEIF makes available a ‘Data Quality Report Dictionary’ relevant to, respectively, the Global LEI Data Quality Report and the LEI Issuer Data Quality Reports, which describe the application of the data quality criteria in practice. Any interested party is invited to review how the figures included in the monthly data quality reports are calculated and how the calculations are implemented. Updated versions of the dictionaries were also published in September 2018.
Data quality in the Global LEI System remains very high
GLEIF has developed a methodology to score the level of LEI data quality. The ‘LEI Total Data Quality Score’ represents the percentage of all LEI data records that have successfully passed checks performed to identify whether the records meet the defined quality criteria. The Total Data Quality Score is indicated with each monthly Global LEI Data Quality Report. Following the introduction of the new and more stringent data quality checks with the Global LEI Data Quality Report published in September 2018, the Total Data Quality Score remained stable, with a score above 99 percent.
This result was confirmed with the data quality reports published in October 2018.
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Stephan Wolf is the CEO of the Global Legal Entity Identifier Foundation (GLEIF). Since January 2017, Mr. Wolf is Co-convener of the International Organization for Standardization Technical Committee 68 FinTech Technical Advisory Group (ISO TC 68 FinTech TAG). In January 2017, Mr. Wolf was named one of the Top 100 Leaders in Identity by One World Identity. He has extensive experience in establishing data operations and global implementation strategy. He has led the advancement of key business and product development strategies throughout his career. Mr. Wolf co-founded IS Innovative Software GmbH in 1989 and served first as its managing director. He was later named spokesman of the executive board of its successor IS.Teledata AG. This company ultimately became part of Interactive Data Corporation where Mr. Wolf held the role of CTO.