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MEMORANDUM

To: Docket EPA-HQ-OAR-2009-0925

From: Lisa Grogan-McCulloch, EPA/Climate Change Division an d Ruth Mead and Amanda Baynham, ERG

Date: March 2, 2010

Subject: Summary of Existing Company Identifier Systems

INTRODUCTION

EPA has identified several government and commercial dat a systems that assign unique numeric or alphanumeric identifiers to individual businesses for the purpose of storing and retrieving data on corporate structure and ownership, and North American Industry Classification System (NAICS) codes. These data systems included: Dun & Brad street Data Universal Numbering System (DUNS), Securities and Exchange Commission (SE C) Central Index Key, Stock Tickers, Committee on Uniform Security Identification Procedures ( CUSIP), International Securities Identification Number (ISIN), Federal Employee Identifi cation Numbers (FEIN), National Institutes of Health (NIH) Electronic Research Admini stration, and LexisNexis. This memorandum provides a brief description of each data syst em.

Dun & Bradstreet Data Universal Numbering System (DUNS)

The Data Universal Numbering System (DUNS) was developed in the 1960s by Dun & Bradstreet to support their credit reporting business. DUNS tracks each individual business entity by assigning each business location a unique 9-digit numerical identifier (referred to as a DUNS number). The DUNS number is used to identify individual bus iness entities in databases maintained by Dun & Bradstreet that contain financial and other company data (including Standard Industrial Classification (SIC) and NAICS codes) . Dun & Bradstreet provides limited use of this data to individuals, businesses, organizations, and governments for a fee. The data is collected from a variety of sources, including telephon e interviews, company financial documents, court and legal filings, business registries, go vernment records, and publications. DUNS numbers are widely used today both nationally and in ternationally by governments, industry, and other organizations. The database currently c ontains more than 29 million entities

in the United States and 150 million entities worldwide. To be included in the database, businesses must apply for a DUNS number. There are no restrictions of the type of entities that can be assigned a DUNS number. For example, DUNS numbe rs are assigned to both public and private entities, non-profit organizations, or small fa mily owned businesses. 1

Dun & Bradstreet also uses the DUNS numbers to track c orporate family structures by linking DUNS numbers for each entity to its parents, subsidiar ies, headquarters, and branches. Using

1 Dun & Bradstreet: DUNS Number, http://www.dnbgov.com/data_duns.html , accessed March 1, 2010.2

this system, Dun & Bradstreet assembles corporate family trees, which identify the highest-level parent company both at the country level and globally. D UNS numbers are linked only when one business location has a financial and legal responsi bility for another location. Legal and financial responsibility is established only when one ent ity owns more than 50% of the other (e.g., a parent company owns 60% of a subsidiary). Consequen tly, Dun & Bradstreet’s corporate trees do not include business relationships where one corpora tion owns only a minority interest in another or where ownership is split between two or mo re companies). 2

Securities and Exchange Commission (SEC) Central Index Key

The Securities and Exchange Commission (SEC) issues a Central Index Key (CIK) number to business entities required to file quarterly and annual finan cial statements with the SEC. The CIK is a 10-digit number and is used to identify the filings o f a company, person, or entity in several online databases, such as the Electronic Data-Ga thering, Analysis, and Retrieval (EDGAR) system. Since CIKs are issued only to business entities required to file disclosures with the SEC, privately held companies do not have CIK n umbers. 3

Stock Symbols

Stock symbols (sometimes called stock ticker symbols ) were developed by Standard & Poor’s and are unique identifiers assigned to each security traded o n U.S. financial exchanges. For example, stock symbols are assigned to publicly traded shar es of a company’s stock traded on an exchange. While stock tickers are specific to a corporati on listed on an exchange, they are not unique to the company, as the same company may have differe nt stock tickers on different exchanges or different tranches of stock listed on the sa me exchange. The stock symbols consist of one to five letters and may have additional suffixes or letters to differentiate between different types of stock (e.g., preferred and common stock). Only publicly traded companies have stock ticker symbols.

Committee on Uniform Security Identification Procedures ( CUSIP)

The Committee on Uniform Security Identification Procedur es (CUSIP) Service Bureau assigns National Securities Identification Numbers (usually cal led CUSIPs) to all securities issued in the United States and Canada by municipalities, governments, corp orations, and other business entitities. CUSIPs are nine-character alphanumeric identifiers that are used to facilitate the

settlement of trades. The first six characters of e ach CUSIP identify the issuer of the security and are referred to as the Issuer Number. The remaining t hree characters include two characters (numerical or alphabetic) used to identify the security a nd one character used as a check digit. CUSIPS are assigned to a wide variety of securities, i ncluding common stock, preferred stock, corporate bonds, annuities, municipal bonds, derivatives, s yndicated loans, and U.S. Treasury Notes. Only entities that have issued securities have a n assigned six character CUSIP Issuer Number. Information on corporate mergers, acquisitions , and name changes is also tracked in

2 Dunn and Bradstreet: Corporate Linkage, http://www.dnbgov.com/data_corporate.html , accessed March 1, 2010.

3 U.S. Securities and Exchange Commission, “Draft EDGAR Filer Manual”, Volume I, Version 8, September 2009 (http://www.sec.gov/info/edgar/edgarfm-vol1-v8_d.pdf).3

the CUSIP database. Access to the information in the CUSIP database is restricted and requires licensing agreements and fees. 4

International Securities Identification Number (ISIN)

The International Securities Identification Number (IS IN) is a unique twelve character alphanumeric identifier issued to securities, such as deb t securities, shares, options, derivatives,

and futures. It is similar to the CUSIP but is used for all types of securities, not just those traded in the U.S. and Canada. Unlike stock symbols which vary by stock exchange, the ISIN is unique to the security and does not change when the security is t raded on a different exchange or other trading platform. ISINs must conform to International Standards Organization (ISO) 6166 and consist of three parts: (1) a two letter country code; ( 2) a nine character alphanumeric security identifier (called the National Securities Identifying Num ber (NSIN)); and (3) a check digit. The NSIN is assigned by governing bodies in each country. In the U.S., the NSIN is assigned by the CUSIP Service Bureau. CUSIPs can be converted to ISINs by adding the country code to the beginning of the CUSIP and an additional check digit to th e end. As with CUSIPs, ISINs are

limited to entities that have issued securities. 5

Federal Employer Identification Numbers (FEIN)

Federal Employer Identification Numbers (FEIN) are unique 9-digit numbers assigned by the Internal Revenue Service (IRS) to business entities oper ating in the United States. The IRS uses FEINs to identify taxpayers that are required to file v arious business tax returns. Business entities that have one or more employees are require d to obtain a FEIN. FEINs are issued to a variety of public and private business entities, including c orporations, partnerships, non-profit organizations, limited liability companies (LLCs), and gove rnment agencies. FEINs are subject to IRC section 6103. The regulation states that all info rmation included on a tax return is

confidential unless the information "does not include data in a form which cannot be associated with, or otherwise identify, directly or indirectly, a particular taxpayer." Furthermore, the regulation is very specific on the conditions under which taxpayer information may be released to employees or officials of the Executive Branch agencie s, and EPA’s collection activities are not covered under any conditions set forth by the regulat ion. Therefore, absent a legislative change, EPA cannot require FEIN. 6

National Institutes of Health, Electronic Research Ad ministration

The National Institutes of Health (NIH) Electronic R esearch Administration maintains a database of grantee organizations that have previously registered w ith NIH. Each entity listed in the database is assigned a unique Institutional Profile File (I PF) number, which is used by the National Institutes of Health for tracking grant awards. IPF numbers are assigned only to

4 CUSIP Global Services, “Inside the CGS Identificatio n System”, https://www.cusip.com/cusip/pdf/Inside_CGS_09-12-02.pdf.

5 Association of National Numbering Agencies, http://www.anna-web.com/index.php/home/isinsaiso6166 , accessed March 1, 2010.

6 Department of the Treasury, Internal Revenue Service , “Understanding Your Employer Identification Number (EIN)”, Publication 1645 (Rev. 12-2009), Catalog Number 14332X, http://www.irs.gov/pub/irs-pdf/p1635.pdf

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companies, organizations, or institutions that have or have had grant support from the NIH. The

database also includes the location and DUNS number for each entity listed in the database. The database currently contains approximately 17,500 registered en tities. 7

LexisNexis

LexisNexis provides a wide range of public records through sea rchable databases for which users pay subscription fees to access and use the data. LexisNe xis’ Directory of Corporate Affiliations database maintains records of corporate ownership. The database covers both U.S. and international businesses and contains records for approxi mately 210,000 public and private companies. The data includes information on parent companie s, affiliates, subsidiaries, and divisions. Each company record includes a unique company identi fier number, SIC and NAICS codes, company hierarchy (including the highest-level parent c ompany), and other ownership information (including percentage of ownership). There is no facility-level data in the database. The database maintains data on several different types of company relationships. These include subsidiaries where the parent company owns more than 50% o f another company, joint ventures where two or more companies share ownership, affiliates where the parent company owns less than 50% of another company, divisions of a company, bra nches, factories, and plants. The information is collected from publicly available document s (e.g., court records, financial disclosure statements, and press releases) and directly from companies. 8

The Directory of Corporate Affiliations focuses primarily on larger companies that have annual revenues exceeding $10 million. Information on small busine sses is generally not available from this source. The directory includes both private and publicly traded business entities and includes records for all major publicly traded companies that have U.S. headquarters (approximately 6,000 U.S. public parent companies and 40,000 subsidiarie s), approximately 50,000 privately held parent companies, and 26,000 privately held sub sidiaries. There is a separate sub-directory for international companies (i.e ., those whose highest-level parent company is located outside the U.S.), which contains rec ords for approximately 16,000 international parent companies. 9

7 U.S. Department of Health and Human Services, Electronic Re search Administration, http://era.nih.gov/commons/index.cfm , accessed March 1, 2010.

8 Lexis Nexis: Corporate Affiliations, http://www.corporateaffiliations.com/ , accessed March 1, 2010.

9 Lexis Nexis: Corporate Affiliations, http://www.corporateaffiliations.com/ , accessed March 1, 2010.