Last week we fielded several phone calls from clients asking about what other challenges the CICI Utility might be facing in addition to the duplicates and empty fields that were described in a recent article from Waters Technology: Data Validator Criticizes DTCC’s Identifier Database. We’re major supporters of the Legal Entity Identifier and we’re confident that it will eventually achieve most of the objectives the industry is setting for it. But getting there will take time.

Alacra pulls down the CICI file every day as part of our work with Compliance and Reference Data departments. Since we had a number of client inquiries regarding data quality, we conducted an analysis of the data in the CICI Utility. As of Friday April 26, here’s what the file looked like:


Source:, April 26, 2013. Total number of entities was 71,793.

Entities from 140 different countries (even Iraq!) have been assigned a CICI. Nine countries have over 1000 entities with a CICI. As we would expect, the United States dominates in CICI registration because the regulatory mandate at this point is exclusively from the CFTC.


Source:, April 26, 2013, April 26, 2013. CICIs by Country (top 12 only).

In addition to the duplicates that were highlighted in the Waters Technology article there are numerous issues with the address information. For example, there are many entities where the State is in City field and the City is in the State field:


There are also errors such as misspellings within the address field. Notice the spelling of Kentucky in the entity details below


If you looked in the database for all the US States that could possibly be in the State field for a US entity, you would think there would be 50, or perhaps a few more if you include Puerto Rico, Guam and other territories. In fact, there are 169 States listed due to misspellings like Deleware and Cailfornia .

A final set of issues has to do with the Legal Form category in the CICI record. Of the 50,000+ Certified Entities, over 20,000 or 40% are categorized as “Other”.


Source:, April 26, 2013, April 26, 2013. Top legal registration types only.

The information on the CICI Utility website is neither clear nor informative:

“The Legal Form attribute is dependent upon the jurisdiction of the entity. Oftentimes, the legal form of an entity is appended to the Legal Name. This field is updated dependent upon the registered country that is selected.” – Legal Form detail.

While the field may be dependent on the jurisdiction, the number of “Others” is too high; especially with entities that should be easily classified and are not. This entity, for example, is an ETF:


The goal here is not to tear down the CICI Utility or to cast doubt on the viability of the Global LEI System (GLEIS). Rather, we are pointing out that the current dataset has issues that need to be resolved. Firms planning to load and use this data for compliance or counterparty analysis need to take care to understand the current limitations to benefit from the CICI Utility as it was intended.

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