A View from the CLOUD (Sibos 2011): Legal Entity Identifiers (LEIs)

As we head into Sibos 2011 in Toronto, one topic already appears to loom large at SWIFT’s annual gathering of leading financial services firms and their customers from around the globe: Legal Entity Identifiers or LEIs.  DTCC and SWIFT are to be applauded for their recent mandate to lead the industry’s global efforts to develop a consensus on the requirements and standards for a viable, uniform and global ID allowing for consistent identification of parties to financial transactions. With Dodd-Frank’s rule makings by the SEC and CFTC pressing the issue, there is no time to waste in creating this universal LEI standard.

The Physical Geography of Finance

However, similar to healthcare and other industries, the current approach to LEIs is trapped in what CLOUD would call a physical geography of finance.  The very fact that a universal LEI standard is being built only for financial markets makes clear the narrow and limited thinking being applied to this critical counter-party problem.  Legal entities are not unique to finance, so why are we building an identifier that is limited to one industry silo? Clearly, the systemic risk we are seeking to balance in the financial system does not just occur between banks. The very risks to which banks are exposed come from the credit they extend to other corporate entities, but the LEI starts at the institution level and not at the very critical data level where the patterns of risk are to be found.  CLOUD’s vision for the future of the Internet will not change the short-term approaches to the LEI, however, it is useful to understand our thinking to know what will be possible in the future.

Electronic Health Records for the Health of the Financial Industry

To help frame the issue, I will lift an example from the realm of CLOUDHealth, rather than CLOUDFinance. Financial statements really aren’t too different from an electronic health record, however, instead of revealing the health of a patient, they reveal the health of a company. Electronic health records (EHRs), like financial statements, remain trapped as digital manifestations of their paper-based cousins. The longer we see the Internet as an electronic courier service of documents, the longer we will miss the systemic opportunities represented by this powerful shift in technology.  As I stated in a recent opinion piece in Interactive Business Reporting magazine, “Our modern digital paper gives us the opportunity to dynamically and rapidly assemble information at its point of consumption, rather than at the point of creation.”

Focusing on the Systemic Risk Rather than the LEIs

Rethinking Data in the CLOUD

We appear to be more focused on the creation of LEIs than we are on the problem they are intended to solve. If the problem is systemic risk, then it would appear that we need to have the ability to build a customized EHR for the health of the financial system.  If we create a pull-based, dynamic and secure environment for information, then we will no longer be dependent on the current push-based approach to financial statements. We can create our own financial statements, assembling only the industry-wide information we need to discern critical patterns in the data, linking the data to the LEI if that is necessary to follow the audit trail to its necessary conclusion.

And, that is the challenge with LEIs, they will continue to depend on the company to act as the silo in which data must be held. All of our efforts with systemic and counter-party risk are on the creation end, rather than the consumption side.

To Be Continued…

CLOUDDimensions: Monetary Instruments Though the Lens of WHO, WHAT, WHEN & WHERE (Part 1 – Checks)

As I was reading through my opinion piece from Sibos 2010, so graciously included by the editors in the latest SWIFT Dialogue magazine, a number of additional thoughts began to strike me about our monetary instruments and the sheer number of tags that intersect through them.

Late last year, I put together a series of posts in the standards section of our CLOUD website on the dimensions of CTML, outlining the basics of WHO, WHAT, WHEN and WHERE I Am™.  Each of these individual posts looked at these dimensions through the lens of an individual, however, these axes can extend beyond people.  They are equally capable of being applied to other physical artifacts, like our monetary instruments, the most common of which are check, debit cards and credit cards.

The goal of this discussion is to explore these four dimensions and how they intersect through our monetary instruments, starting with the most traditional of instruments, a check and then building on this same exercise with other instruments like credit and debit cards.  These individual posts on monetary instruments will lay the foundation for a broader whitepaper on payment systems and how they could work in a future CLOUD-enabled Internet.  I’m looking forward to the work session on the payments landscape in 2011 at SWIFT’s Operations Forum – Americas in NYC next week to get a better sense of the industry’s current thinking on the topic.

As you read through this thinking, it may be useful to pull out a check from your wallet, purse, briefcase or office drawer and take a look at it from the view of CLOUD’s dimensions. The first thing I noticed when I looked at one of my own checks was the fact that there are three separate instances of a WHO tag on this piece of paper.  One of these WHO tags is in the top left and bottom right corners of most checks.  In the case of my check, my name, my wife’s name and our address is in the top left corner.  This same exact tag is also found in the bottom right corner. Of course, in this case, the WHO tag is represented as a machine-readable number, my account number, but in essence, it represents the same information that is found in the top left corner.

The next set of WHO tags is found in the bottom left-hand corner of the check and not far above it in the same region of the check.  This WHO is both the human-readable and machine-readable tags representing the bank that holds my account. The machine-readable tag is commonly known as a routing number.  The final WHO tag is the one which we write on the “Pay to the Order Of” line.  It indicates to whom these funds will be remitted.

Before moving on to the WHAT I Am and WHEN I Am™ tags found on our checks, it is important to point out that a check is not actually money (obvious but worth restating).  In a sense, it is a distribution tag that states how my funds are to be moved.  The same is true of debit and credit cards.  They aren’t money either.  They, too, are distribution mechanisms that state how, when and under what terms money is to be exchanged.  I won’t dwell on the topic here, but it is possible, and very likely, that we each have not only checks that we use for our banking relationship but debit cards and credit cards that come from the same institution.  In the case of the debit card, it really isn’t a different monetary instrument at all but simply another distribution tag that streamlines the paper process of a check.  And, for that matter, the credit card is the same as the debit card, except I’m not moving the underlying funds from my own account but “borrowing” them under specific credit and interest terms for the money that I will have available to me in the future, just not now.  More on this line of thinking later…

So, let’s return to our check and the CLOUD Dimensions associated with it.  In the top right hand corner of our check, we have a line for the date, something we call WHEN I Am in the language of CTML.  This WHEN I Am could be today or a date in the future.  It is a way of saying to the payee and the bank when the funds can be exchanged. We also have a place for a WHAT, which we represent both numerically and in words.  Of course, I’m referring to the amount of funds to be exchanged.

What I discovered going through this exercise is that this one ‘monetary instrument’ is basically a large physical tag cloud to use an Internet term.  On this one piece of paper, there are a significant number of tags, each representing not only a unique piece of information but also representing a number of interacting relationships, all of which have “context” because the tag cloud all occurs on this one piece of paper.  The next post on CLOUD Dimensions and monetary instruments will look at this idea of tag clouds and their representation by credit and debit cards.