The Legal Entity Identifier: The Value of the Unique Counterparty ID The Legal Entity Identifier: The Value of the Unique Counterparty ID Contents Executive Summary 2 The Legal Entity Identifier: A Global Solution for Identifying Trade Counterparties 5 The Business Case for the LEI: From Counterparty Identification to Business Value 10 Capital markets 11 Commercial transactions (B2B commerce) 15 Commercial credit 19 Scaling Adoption of the LEI 22 2 The Legal Entity Identifier: The Value of the Unique Counterparty ID Executive Summary When the collapse of Lehman Brothers—at on recommendations developed by the the time the world’s fourth-largest invest- Financial Stability Board, market authori- ment bank—sparked a global financial cri- ties worked with private-sector entities to sis in 2008, regulators and capital markets create the Global Legal Entity Identifier players needed to quickly assess the extent System (Global LEI System), which serves of market participants’ exposure to the as a publicly available, global directory of bank and each of its hundreds of subsidiar- legal entities. ies. Like many other capital markets partic- The Global LEI System assigns 20-digit, ipants, Lehman Brothers transacted from a alphanumeric Legal Entity Identifiers (LEIs) maze of affiliate and subsidiary legal enti- to uniquely identify legal entities partic- ties (Exhibit 1), and there was no standard ipating in transactions worldwide. Each global identification system for each finan- LEI contains information about an entity’s cial counterparty within that maze. Con- ownership structure and thus answers the sequently, financial regulators and market questions “who is who” and “who owns participants found it impossible to reliably whom” among market participants. At assess counterparties’ exposure to Lehman’s present, capital markets participants who entities and to each other. trade over-the-counter (OTC) derivatives The financial crisis thus laid bare the crit- are the early adopters of the LEI, using the ical need for a system to identify and un- unique identifier for transaction reporting derstand exposures at the legal-entity level to regulators. instead of the aggregate, parent-company However, the LEI has much broader poten- level. If it had been available at the time, tial applications; for example, banks can a system that assigns electronic, standard use them to issue loans, and corporations identifiers to legally distinct parties would can use them to verify the identities of their have helped to fill this gap. sellers, suppliers, and other counterparties. The 2008 financial crisis made influential In general, the LEI creates business value organizations like the Group of 20 (G20), in two ways: first, it reduces transactional the Financial Stability Board, and regulators and operational friction in the identifica- keenly aware of the need for a universal tion of transaction counterparties. Second, system to identify legal entities, and they it makes important information about the began to call for its development. Based background of a legal entity in a particular The Legal Entity Identifier: The Value of the Unique Counterparty ID 3 Exhibit 1 Lehman Brothers Holdings Inc. Lehman Neuberger Lehman LB 745 Lehman Lehman LBHIs “Aviation” Lehman Lehman Brothers legal Berman Brothers LLC Brothers ALI subsidiaries (includes Brothers Brothers Holdings Inc. Commercial Inc. CES Aviation LLC, CES Bancorp OTC entity structure LLC Corporation Aviation V LLC and CES Inc. Derivatives Aviation IX LLC) Inc. Aurora Bank, 1. Woodlands Commercial Bank FDB 2. Lehman Brothers Trust . Company N.A. ENC 3. Lehman Brothers Trust Mortgage Company of Delaware LLC Lehman Lehman Lehman Property LBI Lehman Leveraged Brothers Brothers Brothers Asset Group Commercial Loan Trading . Special Derivative Financial Manage- Inc. Paper Inc. Holding Financing Products Products ment Inc. Partners Lab Inc. Inc. Leveraged Lehman Fondo de Lehman PAMI Structured East Meril Loan Trading Brothers Inversion Scottish LLC Asset Dover LLC Holdings Inc. Commodity Multimerca Finance . Securities Limited . Services do Credito L.P. Corp. Luxembourg Inc. Privado Trading Finance S.a.r.l. LB Rose PAMI LB LB LB 2080 Luxembourg Ranch Stadler Somerset Preferred Kalakaua Residential LLC Arms LLC Somerset Owners . Properties LLC LLC LLC Loan Finance . S.a.r.l Note: Blank boxes for illustrative purposes Source: SEC ling transaction more accessible and traceable. division recently found that it had an aver- Collectively, these benefits reduce the time age of five names—with minor variations spent on identifying counterparties and im- in its database—for the same organization. prove the reliability of information. Additionally, commonly used databases and different divisions and IT systems within Current identification and verification organizations can all have varying versions processes have significant manual compo- of the same entity’s name, making it harder nents and often require the use of multiple to trace and to link information from databases in which a counterparty may be multiple sources. identified by different names. Many banks and corporations still use names rather This paper discusses three use cases that than identifiers, resulting in confusion. As demonstrate the wide potential application an example, a large bank’s client services of the LEI. These use cases—which are not 4 The Legal Entity Identifier: The Value of the Unique Counterparty ID meant to be exhaustive—relate to capital ance of letters of credit. Further savings are markets, commercial transactions, and the likely from the reduction of spend on seller extension of commercial credit. The use identification for e-invoicing, and from a cases and benefits are especially relevant more automated process for commercial to large corporations, small businesses credit extension. and their banking institutions, and in- The use cases described in this paper repre- vestment banks. sent a small percentage of potential savings. In capital markets, the LEI’s primary Introducing the LEI into almost any process value is derived from reducing the cost that requires identification and verification of onboarding clients and of middle- and of a counterparty—and that has a manual back-office activities related to the process- component—can deliver efficiencies and ing of stocks, bonds, and other securities greater reliability. trades. In commercial transactions, LEIs en- As with any identifier, the broad applica- able faster processing of letters of credit and tion of the LEI depends on network effects better identification of sellers on e-invoicing within each industry subgroup. Key benefi- networks. And in the process of extending ciaries of new uses of the LEI should work commercial credit, the use of the LEI allows with each other and their counterparties to for more robust and efficient know your discuss the adoption of the LEI in day-to- customer (KYC) diligence on borrowers, as day processes. well as better traceability of information on borrowers from multiple sources. □ □ □ These benefits yield quantifiable value. Our This paper is a collaborative effort by the analysis suggests that savings of at least Global LEI Foundation and McKinsey & 10 percent of total operations costs for cli- Company to increase awareness of the LEI, ent onboarding and trading processing for including the potential capabilities and banks adopting the LEI are possible. For business benefits afforded by LEI adoption. the broader investment banking industry McKinsey served as a knowledge partner alone, this would yield savings of over $150 to GLEIF in researching and writing the million annually. Banks in trade financing paper. In the pages that follow, we explain could save an additional $500 million per the LEI in detail and describe three import- annum overall by using the LEI in the issu- ant use cases. The Legal Entity Identifier: The Value of the Unique Counterparty ID 5 The Legal Entity Identifier: A Global Solution for Identifying Trade Counterparties The LEI and its beginnings The 2008 collapse of the world’s That maze still exists, and is further com- fourth-largest investment bank, Lehman plicated by the fact that most entities have Brothers, and the subsequent global finan- multiple identifiers that are used for differ- cial crisis exposed—among many other ent purposes. For example, local business systemic vulnerabilities—a critical need register codes that vary by country of incor- to implement a system that would assign poration, tax identification numbers such unique identifiers to legally distinct entities. as the Value-Added Tax (VAT) number in After Lehman’s demise, participants in the the European Union (EU) or the Employer global financial system could not assess Identification Numbers (EIN) in the United their exposure to Lehman, its subsidiaries, States, various sectors’ company registers and each other because there was no stan- such as the Commercial and Government En- dard system for identifying counterparties tity codes for U.S. defense contractors, and in the maze of subsidiaries and affiliates payments I.D.s such as the Business Identifier from which banks, insurers, asset manag- Code (BIC). ers, and other market participants transact. Moreover, many entities share their names The needed information was technically or part of their names with other, similar en- available somewhere among the thousands tities. For example, a bank can have multiple of documents signed by Lehman’s hundreds identifiers and share its name, or