Where standards get down to business © 2011 GS1US

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GS1 Proposal to the SEC, CFTC, and OFR 

Regarding Unique Identification and Reference 

Data – Technical Details 

8 June 2011
Where standards get down to business © 2011 GS1US

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GS1 Solution Outline

• GS1 System in use for nearly 40 years by over 25 i ndustries

• Existing legal entity identifier (the “GLN”)

• Over 1.5 million in use today

• Self-assignment based on GS1 Global Company Prefix

• Existing US registry for legal entity identifiers (the “GS1 US 

GLN Registry”)

• Nearly 300,000 legal entity identifiers self-registered

• Core set of 28 reference data attributes – including 10 of the 19 

identified in the SIFMA-led requirements document

• Existing global reference data synchronization network (the 

“GS1 Global Data Synchronization Network”)

• 6.8 million identifiers self-registered worldwide

• 1000s of reference data attributes for each identifier

• 132 countries served

• 28 federated data pools world wide

• Identification system extensible to instrument / contract, 

financial event / corporate action, and transaction identifiers

<gln>0614141000012</gln>

GS1 US GLN 

Registry
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How It Works – Use Cases

• These slides illustrate typical use cases for allocation and use of LEIs and their 

reference data, as they would work under the GS1 proposal

• Use case #1: A company wants to create new LEIs for two operating divisions.

• Use cases #2 – 3: A company wants to register an LEI for use in financial 

transactions

• Use case #2 – core attributes only (short term solution)

• Use case #3 – extended attributes, using RDRA (long term solution)

• Use case #4: A company wants to obtain reference data regarding an LEI it 

encountered in a financial document

• Use case #5: A data provider assists in enhancing a company’s legacy data with 

LEIs, in the context of a regulatory request for information

• Use case #6: A regulator audits the reference data associated with an LEI

• Use case #7: A company spins out a new corporate entity
Where standards get down to business © 2011 GS1US

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Identifier Self-Assignment Using GS1 Global 

Company Prefix (GCP)

• GS1’s Legal Entity Identi fier (the “GLN”) is a 13-digit 

number:

0614141 00001 2

First few digits 

assigned by GS1 to a 

company – globally 

unique. Company now 

has capacity to selfassign many LEIs

“GS1 Global Company 

Prefix” (GCP)

Remaining digits selfassigned by a 

company to create a 

single LEI

13th digit is a “check 

digit”, calculated from 

the other twelve digits 

(helps avoid keying 

errors)
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Use Case #1: A company wants to create new 

LEIs for two operating divisions 

GS1 Member Organization Company

1. Company needs an 

LEI for its XYZ division

1. Company needs an 

LEI for its XYZ division

2. Company requests 

a GS1 Company 

Prefix (GCP)

2. Company requests 

a GS1 Company 

Prefix (GCP)

3. GS1 confirms identity 

and status of requesting 

organization including 

validating financial 

regulatory jurisdiction and 

certification authority

3. GS1 confirms identity 

and status of requesting 

organization including 

validating financial 

regulatory jurisdiction and 

certification authority

5. Company records its 

GS1 Company Prefix

5. Company records its 

GS1 Company Prefix

The GS1 Company Prefix gives the 

company the capacity to issue 10 –

1,000,000 LEIs

A 11-digit prefix gives capacity for 10 LEIs, 

a 10-digit prefix gives capacity for 100 

LEIs, and so on. Capacity is matched to 

company’s needs.

GCP

GCP Request

6. Company creates an 

LEI for XYZ division by 

adding digits to its GCP 

to form a 13-digit LEI

6. Company creates an 

LEI for XYZ division by 

adding digits to its GCP 

to form a 13-digit LEI

7. Company needs an 

LEI for its ABC division

7. Company needs an 

LEI for its ABC division

8. Company creates an 

LEI for ABC division by 

adding digits to its GCP 

to form a 13-digit LEI

8. Company creates an 

LEI for ABC division by 

adding digits to its GCP 

to form a 13-digit LEI

The company did not need to return to GS1 

to allocate the new LEI. LEIs are selfallocated once a GS1 Company Prefix is 

obtained Ë faster, lower cost.

A company may obtain another GS1 

Company Prefix if it exhausts the capacity 

of the first.

Candidate LEI for XYZ: 0614141000012

Candidate LEI for ABC: 0614141000029

GCP: 0614141

The actual LEI creation is 

done by the company acting 

on its own

This is just a candidate LEI 

at this stage; it must be 

registered prior to use in 

financial transactions (see 

Use Case #2)

4. GS1 allocates a 

unique GS1 Company 

Prefix (6-11 digits) and 

records the GCP in its 

GCP Registry

4. GS1 allocates a 

unique GS1 Company 

Prefix (6-11 digits) and 

records the GCP in its 

GCP Registry

GS1 Company 

Prefix (GCP) 

Registry
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Variable-Length GCP Accommodates Varying 

Capacity Needs

GS1 

Member 

Organization

GS1 

Member 

Organization

GS1 Company 

Prefix Database

0614141 12345 2

Large Company

7-digit GCP

5-digit Entity # 

(capacity for 100,000 

different LEIs)

LEI = 0614141123452

Small Company

11-digit GCP

GCP = 0614141

GCP = 08699999999

08699999999 1 3

1-digit Entity # 

(capacity for 10 

different LEIs)

LEI = 0869999999913

Tiny Company

One LEI

Individual LEI = 

0181234567894

LEI = 0181234567894
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“Non-intelligent” Numbers

• The GS1 Global Company Prefix is a means to allocate numbers, not to encode 

their relationships

• The meaning of a number is contained in its reference data 

• Two LEIs sharing common prefix are not necessarily related

• Two related LEIs do not necessarily share common prefix

• Example: Merger

• Company A (LEI = 0614141000012) buys Company B (LEI = 033333000005), and 

operates it as a subsidiary

ß Afterward, B’s LEI is still 033333000005

• Example: Spin-out

• Company A (LEI =0614141000012) spins out its XYZ subsidiary (LEI = 0614141000029)

ß Afterward, XYZ’s LEI is still 0614141000029

• Conclusion: corporate relationships are understood through reference data, not 

by parsing the numbers
Where standards get down to business © 2011 GS1US

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Use case #2: A company wants to register an 

LEI for use in financial transactions – core 

attributes only

Company

1. Company creates a 

new candidate LEI 

(Use Case #1)

1. Company creates a 

new candidate LEI 

(Use Case #1)

2. Company defines 

reference data for LEI

2. Company defines 

reference data for LEI

3. Company submits 

LEI and reference data 

to its preferred auditor / 

certifying authority

3. Company submits 

LEI and reference data 

to its preferred auditor / 

certifying authority

5. Company registers 

LEI and core attributes 

with GS1 LEI registry

5. Company registers 

LEI and core attributes 

with GS1 LEI registry

4. Auditor / authority 

certifies accuracy of 

core reference data

4. Auditor / authority 

certifies accuracy of 

core reference data

GS1 LEI 

registry

6. GS1 verifies 

LEI’s GCP, 

certification

6. GS1 verifies 

LEI’s GCP, 

certification

LEI,

Ref Data

LEI, core attrs, certification

GS1 LEI Registry stores 

a small number of core 

attributes

This step may be subject to 

local regulation

The content of reference data is set by industry 

standards (e.g., minimum data sets, XBRL templates). 

The standards take regulatory mandates into account.

Auditor / Certifying 

Authority

Certification

GS1 Company 

Prefix (GCP) 

Registry

GS1 LEI 

Registry

7. GS1 records 

LEI,and core 

attributes

7. GS1 records 

LEI,and core 

attributes
Where standards get down to business © 2011 GS1US

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Use case #3: A company wants to register an 

LEI for use in financial transactions – with 

extended attribute using RDRA

Company

1. Company creates a 

new candidate LEI 

(Use Case #1)

1. Company creates a 

new candidate LEI 

(Use Case #1)

Company chooses which RDRA to work with; 

RDRAs can compete for business. In some 

countries, one RDRA may be gov’t-mandated.

2. Company defines 

reference data for LEI

2. Company defines 

reference data for LEI

3. Company submits 

LEI and reference data 

to its preferred auditor / 

certifying authority

3. Company submits 

LEI and reference data 

to its preferred auditor / 

certifying authority

7. RDRA registers LEI 

and core attributes with 

GS1 LEI registry on 

behalf of Company

7. RDRA registers LEI 

and core attributes with 

GS1 LEI registry on 

behalf of Company

10. RDRA stores 

extended ref data, 

acknowledges

10. RDRA stores 

extended ref data, 

acknowledges

11. RDRA 

synchronizes with other 

RDRAs via GS1 Global 

Data Sync Network 

11. RDRA 

synchronizes with other 

RDRAs via GS1 Global 

Data Sync Network 

4. Auditor / authority 

certifies accuracy of 

reference data

4. Auditor / authority 

certifies accuracy of 

reference data

Reference Data 

Registration Authority 

(RDRA) #1

GS1 LEI 

registry

Other RDRAs Worldwide

9. GS1 records 

RDRA #1 as 

“home” RDRA for 

this LEI, plus core 

attributes

9. GS1 records 

RDRA #1 as 

“home” RDRA for 

this LEI, plus core 

attributes

12. All other RDRAs

worldwide now have 

copy of reference data 

for this LEI 

12. All other RDRAs

worldwide now have 

copy of reference data 

for this LEI 

LEI,

Ref Data

LEI, 

core 

attrs

LEI, all Ref Data

Acknowledgement

GS1 LEI Registry stores 

a small number of core 

attributes, and a pointer 

to the “home” RDRA, 

not the extended 

reference data.

This step may be subject to 

local regulation

In this case, the reference data includes 

core attributes, plus extended attributes.

A company’s choice of 

“home” RDRA doesn’t affect 

ability to access reference 

data worldwide.

Auditor / Certifying 

Authority

5. Company submits 

LEI and certified 

reference data to its 

preferred RDRA

5. Company submits 

LEI and certified 

reference data to its 

preferred RDRA

Certification

LEI, all Ref Data, Certification

6. RDRA confirms 

incoming reference data 

has certification

6. RDRA confirms 

incoming reference data 

has certification

8. GS1 validates 

LEI’s GCP

8. GS1 validates 

LEI’s GCP

GS1 

Company 

Prefix (GCP) 

Registry

GS1 LEI Registry

RDRA’s DB
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Use case #4: A company wants to obtain 

reference data regarding an LEI it 

encountered in a financial document

Company

1. Company sees 

unknown LEI in a 

financial document

1. Company sees 

unknown LEI in a 

financial document

2a. Company requests 

core reference data 

from GS1 LEI Registry

2a. Company requests 

core reference data 

from GS1 LEI Registry

Reference Data 

Registration Authority 

(RDRA)

LEI

Any RDRA can respond with reference data for 

this LEI because they are all synchronized.

It does not have to be the “home” RDRA for this 

LEI

3b. RDRA looks up LEI in its 

own database, responds with 

reference data

3b. RDRA looks up LEI in its 

own database, responds with 

reference data

4. Company now has 

reference data for this 

LEI

4. Company now has 

reference data for this 

LEI

5. Repeat as 

necessary

5. Repeat as 

necessary

The reference data for the first LEI may contain other LEIs; 

e.g., LEIs of subsidiaries, parents, etc. These can be looked 

up as needed.

Some companies may subscribe to a data feed from their 

preferred RDRA, avoiding the need to do individual lookups.

RDRAs may compete on the basis of subscription and other 

data services that they offer.

Core Reference Data

2b. Company requests 

extended reference data 

from its preferred RDRA

2b. Company requests 

extended reference data 

from its preferred RDRA

GS1 LEI Registry

3a. GS1 looks up LEI in LEI 

Registry, responds with 

reference data

3a. GS1 looks up LEI in LEI 

Registry, responds with 

reference data

LEI

Extended Reference Data

GS1 LEI 

Registry

RDRA’s DB
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Use case #5: A data provider assists in 

enhancing a financial institution’s legacy data 

with LEIs, in the context of a regulatory 

request for information

Financial 

Institution

1. Regulator requests 

info from financial 

institution

1. Regulator requests 

info from financial 

institution

Reference Data 

Registration Authority 

(RDRA)

In the short term, individual financial institutions avoid having to migrate 

legacy systems to standard LEIs; the short term need is met by data 

specialists (RDRAs). Or, financial intitution can do this itself.

Over time, individual financial institution records migrate to direct use of 

LEIs.

Regulator

2. Company retrieves 

info from its legacy 

systems – not yet using 

standard LEI

2. Company retrieves 

info from its legacy 

systems – not yet using 

standard LEI

3. Company requests 

legacy translation from 

its preferred RDRA

3. Company requests 

legacy translation from 

its preferred RDRA 4. RDRA translates 

legacy identifiers to 

standard LEIs

4. RDRA translates 

legacy identifiers to 

standard LEIs

5. Company forwards 

LEI-enhanced info to 

regulator

5. Company forwards 

LEI-enhanced info to 

regulator

Request

Request

Response

GS1 LEI 

Registry

GS1 LEI 

Registry

RDRA’s DB
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Use case #6: A regulator audits the reference 

data associated with an LEI

1. Regulator initiates ad 

hoc investigation 

regarding a specific LEI

1. Regulator initiates ad 

hoc investigation 

regarding a specific LEI

Reference Data 

Registration Authority 

(RDRA) Regulator GS1 LEI 

registry

2. Regulator looks up 

LEI to find core 

attributes and “home”

RDRA for this LEI

2. Regulator looks up 

LEI to find core 

attributes and “home”

RDRA for this LEI 3. GSI LEI registry 

responds with pointer to 

“home” RDRA for this 

LEI and core attributes

3. GSI LEI registry 

responds with pointer to 

“home” RDRA for this 

LEI and core attributes

4. Regulator 

examines core 

attributes

4. Regulator 

examines core 

attributes

5. Regulator makes 

inquiry to “home”

RDRA for this LEI to 

investigate extended 

attributes

5. Regulator makes 

inquiry to “home”

RDRA for this LEI to 

investigate extended 

attributes

LEI

Core attributes +

Pointer to “home” RDRA

GS1 LEI 

Registry

RDRA’s DB
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GS1 System Extended to Instrument, Event, 

and Transaction Identifiers

GS1 Member Organization Company

GS1 Member Organization 

Issues GS1 Company 

Prefix to Company

GS1 Member Organization 

Issues GS1 Company 

Prefix to Company

GS1 Company 

Prefix Database

0614141000012

0614141123452

0614141123452000001

Company assigns entity 

portion to create Legal 

Entity Identifier

Company assigns entity 

portion to create Legal 

Entity Identifier

Company / contract market assigns instrument 

portion to create instrument / contract identifier

Company / contract market assigns instrument 

portion to create instrument / contract identifier

Company assigns event portion 

to create financial event identifier

Company assigns event portion 

to create financial event identifier

Legal Entity Identifier

Financial Instrument/ 

Contract Identifier

Financial Event Identifier

0614141123452000000002

Company assigns transaction portion to create financial transact Company assigns transaction portion to create financial transaction identifier ion identifier

Financial Transaction 

Identifier
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0614141111115 ABC Corp Common 0614141000012 ...

Other 

Attributes

Instrument/ Contract Issuer LEI

Name

Identifier

Financial Instrument/Contract Identifier Database

0614141000012 ABC Corp [none] ...

LEI Company Name Predecessor LEI Other Attributes

LEI Database

Use case #7: ABC Corp spins out new XYZ 

Corp, with common & preferred shares

Company

1. ABC Corp begins with:

-GS1 Company Prefix 0614141

-ABC Corp LEI 0614141000012

-ABC Common Stock FII 0614141111115

1. ABC Corp begins with:

-GS1 Company Prefix 0614141

-ABC Corp LEI 0614141000012

-ABC Common Stock FII 0614141111115

Reference Data Registration 

Authority

2. ABC Corp creates new LEI for XYZ corp: 

LEI = 0614141000028

2. ABC Corp creates new LEI for XYZ corp: 

LEI = 0614141000028

3. ABC Corp creates new FIIs for XYZ corp

common and preferred shares: 

XYZ common FII = 0614141222224

XYZ preferred FII = 0614141222231

3. ABC Corp creates new FIIs for XYZ corp

common and preferred shares: 

XYZ common FII = 0614141222224

XYZ preferred FII = 0614141222231

4. ABC Corp creates new FEI for ABC Corp 

for the event associated with spin-out:

FEI = 0614141000012000001

4. ABC Corp creates new FEI for ABC Corp 

for the event associated with spin-out:

FEI = 0614141000012000001

0614141000028 XYZ Corp 0614141000012 ...

0614141000012 ABC Corp [none] ...

LEI Company Name Predecessor LEI Other Attributes

LEI Database

0614141222231 XYZ Corp Preferred 0614141000028 ...

0614141222224 XYZ Corp Common 0614141000028 ...

0614141111115 ABC Corp Common 0614141000012 ...

Other 

Attributes

Instrument/ Contract Issuer LEI

Name

Identifier

Financial Instrument/Contract Identifier Database

Financial Event Identifier Database

0614141000012

Parent LEI

Spin-out

Type

0614141000012000001 0614141000012 0614141000028

Event Identifier Issuer LEI Spun-out LEI