Using U.S. Business Registry Data to Corroborate Corporate Identity: Case Study of the Legal Entity Identifier

This paper offers a fresh perspective on fundamental issues in using official incorporation records to corroborate the identity of corporate entities by comparing two publicly-available sets of information, namely, business registry incorporation records and reference data from the Legal Entity Identifier (LEI) system, with some focus on the monitoring function performed by LEI issuers as agents for LEI data users. Three modes of analysis are used to consider these issues, high-level analysis of LEI system data about U.S. entities with LEIs, interviews conducted with U.S. business registries, and entity-level comparisons of business registry and LEI records for entities with LEIs incorporated in the states of Ohio and Massachusetts. The fresh perspective provided here includes attention to key comparison issues such as truncation of Legal Names in official records; significant state-level variation in requirements to provide business address information in incorporation records or periodic reports; recognition that some key business register data may not be readily available or available only at a cost; whether in this context enhancements can be made to the expectations for, and disclosures by, LEI issuers in their monitoring role; and to what extent the high incidence of non-renewal of LEIs might play a role in the quality of LEI reference data. The paper develops measures of scope and degree for many key issues that can arise in using business registry information within an identity-corroboration context. The exceptional transparency of the LEI system allows for detailed comparisons that connect its data quality and value proposition with its sources and methods.