Finance – LEI
A long term goal of the project is to develop a consistent and integrated view of a legal entity, a company or institution’s exposure worldwide. In order to succeed regulators need to overcome the obstacle of aggregating and sharing information effectively across borders.
The LEI project was created by the Financial Stability Board (FSB) in response to a call from the leaders of the G20 countries to proceed with development of a “unique identification system for parties to financial transactions”.
The Bank of England asked if OBASHI Ltd. would join the Legal Entity Identifier project as advisers to the G20 and Financial Stability Board as part of the Data Operations and Governance & Legal teams.
The FSB pulled together global experts with backgrounds in financial systems, risk management, banking, trading and legal expertise. Our unique insight into data flow, governance and operational risk across a range of industries proved a valuable asset to the project.
The financial crash of 2008 left the finance industry with many major problems. One of these was being able to quantify the amount of risk to which a legal entity, company or institution is exposed. And in a wider context how the aggregation of entities’ individual risks and exposures may impact the economics of nations and the global economy as a whole.
During 2010 the G20 countries and the FSB agreed to fund and develop a global LEI system whereby all entities that perform a financial trade would be allocated a unique 22 character alpha numeric identifier. Allocation of this Identifier must occur before any trading can commence, and following an exhaustive validation and verification process.
These processes would have to be consistent across jurisdictions around the world. The ongoing management of LEI numbers has to be operated on a global scale as entities relocate into new countries.
Given both the huge complexity of the LEI project and the diverse nationalities and backgrounds of participants there was a clear requirement for a visual common language that would enable simple communication during the conceptual and design phases.
The long term vision for the LEI system is to have a Central Operating Unit (COU) and Local Operating Units (LOUs). This would be a multilayered federated system with stringent Cyber Security controls and the ability to manage and process vast quantities of data.
A simple common language was essential to create clarity and enable understanding between the various global domain experts and the FSB/G20 steering groups.
Using the OBASHI Methodology as a governance framework language, OBASHI Ltd. developed conceptual policy white papers and models for communicating the complex ownership hierarchy relationships that will exist between trading stakeholders and the regulatory authorities.
As part of the project we worked with technical and business professionals to rationalise the design of how the global LEI system could operate and how it would be governed from a dataflow management perspective.
Key design areas for the project centred around the LEI system’s operational processes including information and data assurance, quality control and change control.
The OBASHI Governance Framework Language provided an easy to understand mechanism to contextualise and communicate how all the people, process, assets and dataflows (and their relationships and dependencies) will combine to create LEI operations and the associated governance functions.
The Next Steps
The LEI project is on-going, and after over three years in existence it has recently appointed a board and CEO.
The next major challenge facing the LEI project is the detailed design phase of the LEI system.
OBASHI has used The OBASHI Methodology as a Governance Framework Language to map out the LEI allocation, validation and verification processes for different jurisdictions around the world. This has helped bring clarity to the numerous ways that different countries operate to carry out the same processes, allowing us to highlight a common best practice.
We continue to help and advise the LEI to define best practice around dataflow quality, assurance and integrity as more countries come on board and the project moves through its development phases.
- Legal Entity Identifier – One of the largest financial project in the world
- Developed a governance framework language using OBASHI
- Conceptual – allocation, validation and verification processes modelled using OBASHI
- OBASHI diagrams developed and used across multiple countries
- Ownership hierarchies and associated risk modelled