ACT-IAC White Paper: Unique Entity Identifiers and the Global Legal Entity Identifier (LEI): A Potential Cornerstone for Transparency of Federal Spending Data and the DATA Act

Unique Entity Identifiers and the Global Legal Entity Identifier (LEI): A Potential Cornerstone for Transparency of Federal Spending Data and the DATA Act
Developed by the Financial Management Committee, Collaboration and Transformation Shared Interest Group
Date Released: July 2015

The global Legal Entity Identifier (LEI) is gaining momentum in its adoption across a number of industries both domestically and globally. This new unique entity identifier is a non-proprietary data element that has the capability to provide financial industry stakeholders with a further transparent view into legal entities and financial transactions by revealing the interconnectedness of entities at the granular transactional level. The practical applications of a new unique entity identifier such as the global LEI extend beyond just the financial industry and could further the transparency of Digital Accountability and Transparency Act of 2014 (DATA Act, P.L. 113-101) related data. This document explores the currently available unique identifiers used with DATA Act related data, the key attributes needed for a unique entity identifier and system, an overview of the global LEI, the oversight and governance structures in place for unique entity identifiers to reduce improper payments, fraud, waste, and abuse, as well as the benefits of using a new unique entity identifier for DATA Act related data. This document also explores the key challenges, costs, and other implementation considerations associated with entities migrating to the global LEI that would need to be considered for federal agency systems and business processes.