Add LEI issuer claim

[Naohiro Fujie]

Feedback from METI to the authority claims/regal entity.

Comment:

• there are at least 2 legal entity identifier issuers in Japan, GLEIF, Ministry of Justice.

Proposal:

• add lei_issuer claim for legal entity

"authority": [ {
  "applies_to": {
    "company_name": "Example Company Limited",
    "jurisdiction": "england-wales",
    "lei": "1234567",
    "lei_issuer": "GLEIF"   <-- add issuer of the LEI
  },

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[Mark Haine]

Perhaps a structured object might be better…

"authority": [ {
  "applies_to": {
    "company_name": "Example Company Limited",
    "jurisdiction": "japan",
    "lei": { 
      "number": "1234567",
      "issuer": "GLEIF"
    }
  },

‌

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[Mark Haine]

Following discussion I will raise a PR to update the document

[Mark Haine]

I have done some homework and it would appear that the LEI code itself is a structured string as per… https://lei.info/portal/resources/lei-code/ and the first 4 characters of an LEI are reserved for the LOU (Local Operating Unit) which is the issuer as far as I understand.

I would suggest that as it is embedded in the lei then we should not add issuer.

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[Kosuke Koiwai]

I think what @Naohiro Fujie meant was there are at least two “legal entity identifier” of legal entities in Japan.

One is the GLEIF (in Japan, mainly maintained by Tokyo Stock Exchange), and the other is so-called “legal entity number” maintained by Japanese government (National Tax Agency), and there two are completely different structure and maintained by different framework.

For example, the former “identifier” of KDDI corp is 5299003FU7V4I45FU310 and the latter is 9011101031552.

https://search.gleif.org/#/record/5299003FU7V4I45FU310

https://www.houjin-bangou.nta.go.jp/henkorireki-johoto.html?selHouzinNo=9011101031552

[Naohiro Fujie]

Thank you @Kosuke Koiwai . What I meant is this.

"authority": [ {
  "applies_to": {
    "company_name": "KDDI Corporation",
    "jurisdiction": "Japan",
    "lei": [{ 
      "number": "5299003FU7V4I45FU310",
      "issuer": "GLEIF"
    },{
      "number": "9011101031552",
      "National Tax Agency"
    }]
  },

‌

[Mark Haine]

Following discussion at the working group meeting yesterday I think the consensus was to keep the “lei” claim exclusively for identifiers issued under the governance of GLEIF and ISO17442. I will extend the definition to make that clearer.

With regard to the Japanese National Tax agency number I think we agreed to look at the “registration_number“ and “registered_jurisdiction“ claims and potentially extend them to more completely reflect the issuing body, jurisdiction and other associated attributes.

[Naohiro Fujie]

I have discussed with METI and got feedback for this issue. They said there is no problem to keep the “lei” claim for identifiers issued by GLEIF related organizations, but they still have requirement to have multiple identifiers from different organizations.

So I propose to make registration_number to have structured array values like this,

"authority": [ {
  "applies_to": {
    "company_name": "KDDI Corporation",
    "jurisdiction": "Japan",
    "lei": "5299003FU7V4I45FU310",
    "registration_numbers": [{ 
      "number": "9011101031552",
      "issuer": National Tax Agency"
    },{
      "number": "999999999999",
      "issuer": "some other organization"
    }]
  },

‌

[Mark Haine]

resolved by PR #83