The Entity Problem for Semantic Use of Financial Information on the Web: Global Open Source Entity Reference
This section reports on the break out session on entity naming, and we are greatful to Patrick Slattery for contributing these notes.
The following table summarizes the definitions of some of the terms used in this document. As you read this document, please consider other terms used which may require definition here to help a broad audience of potential readers.
|Avox.de||German government sponsored, open-source entity reference which is made available on the web (www.avox.de) and maintained through public review and submissions to a federal German governance model|
|DNS||Domain Name Search (DNS) model whereby domain names are registered with relevant attributes, including one, or more, appropriate URLs|
|Entity||Partnership, corporation, or other organization having the capacity to negotiate contracts, assume financial obligations, and pay off debts|
|IFRS||International Financial Reporting Standards or the current set of standards and anticipated standards of the International Accounting Standards Board (IASB) which are used as a reference for the preparation and interpretation of publicly available financial reports in countries which require their use|
|OMB||United States Federal Office of Management and Budget, the authority for federal government budgets and estimates in the United States|
|Open Source||Business registration filings per the Uniform Commercial Code (UCC) in the United States of America, typically managed at the state level by the Office of the Secretary of State|
|Semantic Web||Makes use of globally unique identifiers based on URIs, and reliant on the Domain Name System managed by IANA. Reuse of vocabularies is encouraged, but there are mechanisms for relating independently developed vocabularies.|
|UCC Filing||Business registration filings per the Uniform Commercial Code (UCC) in the United States of America, typically managed at the state level by the Office of the Secretary of State|
Financial information is predominantly associated with one, or more, entities. To perform fundamental queries, linkages of data, analysis and reporting of financial information requires a reliable understanding of entities, including: the ability to identify a unique entity and its associated business name and other relevant attributes. No global, open entity reference exists for the use with semantic financial data on the web.
A reliable, authoritative, open source is needed to provide a unique identifier and relevant attributes for entities and hierarchies of entities used with data on the web.
The ideal solution will have the following characteristics.
– The solution should provide a simple and reliable means to uniquely identify an entity in such a manner that the same unique identifier may be used by multiple parties and in multiple applications consistently and reliably.
– The solution should be accessible globally using commonly available web technology. The data referenced in the solution should be global in scope; the solution should provide a means of uniquely identifying any business entity that may be referred to semantically on the web, regardless of where that entity is domiciled. This global scope should include supra-national entities not domiciled in a specific country (e.g. cross-border investment banks, etc.) The solution should provide a collectively exhaustive list of known entities, regardless of whether those entities publicly trade ownership shares on an established exchange, or are privately held.
Confidence Level / Authoritative
– The solution should be designed and maintained in such a way that users may be reasonably confident in the information provided. The solution is not intended as a surrogate for regulatory bodies which permit and register entities in their respective domains. Where practical, the solution should rely upon appropriate regulatory bodies and other means of confirming new data and maintaining existing data. The solution should consider providing a means of citing the regulatory body responsible for the filing of an entity’s legal status, including a web link to that citation, where available.
– The solution should have a robust, reliable governance model which is available for public inspection. The governance model should safeguard confidential information and provide a mean for ensuring the reliability of the data. To the extent practical, the governance model should consider incorporating some form of self-service by interested parties (business entities.)
– The solution should be non-proprietary, that is, it should not exist for the gain or other advantage of an organization or individual. Output from the solution may be re-purposed in value-added and commercial ways, but the primary output should be available freely to the public at no charge.
– The solution should provide persistent information; it should be reliable over time and not subject to arbitrary change or meaningful modification over time, other than routine additions of new data, refinement and edits of existing data and potential deletion of obsolete data when the deletion of data would not cause an undue hardship on those who rely upon the solution.
Hierarchy & Ownership Complexity
– The solution should provide a means of representing the hierarchical relationship between entities which allows users to identify the ultimate parent entity of any entity as well as the relationship of an entity to its immediate parent entity. Where an entity has no immediate parent entity, and, hence, no ultimate parent entity, this information should be readily available as well. Entity relationships should consider some of the more routine complications of the parent-child relationship, such as percentage ownership where material and, where practical, recursive ownership and other complex ownership relationships.
– The solution should be extensible. Entities defined in the solution should have a means available whereby they may rely upon the data provided by the solution and extend that data to include additional entities, internal to their business entity. This may include a further refinement of the entity hierarchy for internal use within a business entity. Consideration should be given to whether the solution’s extensibility functionality should include a feature to support the maintenance of data on a matrix organization; that is, an internal, management organization of entities, or nodes, with more than one owner.
Confidentiality & Permission
– There may be a need for the solution to consider establishing a means of preserving confidentiality for information on some entities and a related process for requesting and granting permission to access confidential information.
Some selected attributes to consider tracking for each entity defined in the solution are presented in the following comments.
Name and Aliases
Each unique entity should have a name associated. As there are often cases where the same entity is referred to by different names, a series of aliases should be available. Consideration should be given to managing any redundant use of names or aliases. Given the scale of the solution it should be understood that names are likely to be used redundantly in many cases. Some means of determining the specific entity identified should be clearly available to help manage the use of redundant names and aliases.
Registration and Contact Information
Similar to domain name registration on the internet, the solution should provide a means of identifying contact information for the individual responsible for information on that entity. The primary use of registration and contact information would be to advise and potentially engaged appropriate contacts in the confirmation and maintenance of data. A facility to make this information private may be provided.
The solution may consider providing a means of tracking some basic business parameters on each entity, such as: business formation type (corporation, association, partnership, etc.), business segment and industry, the jurisdiction where the entity is domiciled, the entity’s statutory currency, the term of the entity’s existence and its next filing date or registration event, and other parameters which are considered to provide an appropriate level of benefit to users of information relative to the incremental cost of their capture and maintenance.
In addition to basic business parameters and the registration and contact information discussed above, the solution may consider tracking information on key individuals, such as board members and officers for corporations and associations, partners for partnerships, etc.
Other entity attributes may be considered during the design and implementation of the solution. These additional attributes, in fact, many aspects of the solution, may be considered part of an target, end-state design, but implemented in stages or releases.
Existing Comparable Models
The following table lists some existing comparable models which are not proprietary.
|DNS System||Open; Universally accessible; Consistent; Reliable||Does not support hierarchies|
|Dutch Ministry of Justice Refactoring to RDF||Similar requirements to determine entities uniquely||Redundant reference data requires manual interpretation effort; Not publicly available; Not global – Dutch|
|IFRS||Mandates self-reporting of parent entity and ultimate parent entity in reporting||No use of a unique key; Not global - limited to IFRS compliant jurisdictions|
|Merged US Federal Agency Concept||Authoritative; Highly visible, which could add to credibility; Engages US federal government as key stakeholder||Conceptual – not implemented; Not global – US; May not be collectively exhaustive even in the US|
|OMB||Similar to Merged US Federal Agency Concept, but may require less change management to implement||Not global – US|
|US State Registries of UCC Filings, Legal Entities||Authoritative sources; Timely||Some states do not make data freely available (e.g. Delaware); Not global – US state-specific|
|Wiki Model (Avox.de)||Distributes maintenance effort to participants||Inadequate governance to ensure authority and confidentiality|
The following table lists some existing comparable models which are proprietary.
|Axclom||Extensive||Internal corporate data, not freely available; Proprietary – governance and utility can be redirected|
|D&B Number||Reliable||Proprietary – governance and utility can be redirected; Not global|
Other Available Resources
Interested participants in the W3C/XII workshop on Improving Access – Financial Data on the Web are available to help refine the concept.
W3C can organize an incubator group and the related support resources (Wiki, mail list, etc.) to facilitate continuing the dialogue.
Within the U.S., there are a number of federal agencies and initiatives with an interest in solving the problem.
Large corporate entities which need to identify entities uniquely for internal reference sets and related transaction record keeping, such vendor, customer and inter-company activity could see a meaningful efficiency opportunity in being able to rely upon a global, open-source entity reference and may be interested in providing insight and support in the design of the solution.
Leadership is required. Given the global requirement, determining, soliciting and engaging that leadership will be critical.
Proposed Next Steps
- Refine these notes
- Develop a disclosure draft of the concept and solicit stakeholder feedback
- Develop and begin to manage a plan for the design and implementation of the solution
An incubator group would refine these next steps and the related plan.