Challenge Policy

Clause 1: Objective and Scope

This Challenge Policy establishes the formal framework and public right to challenge Legal Entity Identifier (LEI) data managed or issued by LEI International Pvt. Ltd. (TNV-LEI), in alignment with the Global Legal Entity Identifier Foundation (GLEIF) Challenge Process Manual (Version 1.3, January 2025), ISO 17442, and the GLEIF Master Agreement.

TNV-LEI, as a Candidate Local Operating Unit (LOU) (GLEIF ID: 9269), acknowledges its obligation to provide transparent, fair, and non-discriminatory procedures that allow any natural person or legal entity to submit a challenge regarding the accuracy or completeness of LEI reference data.

This Policy applies to:

• All LEIs issued or managed by TNV-LEI
• All forms of Level 1 data (Legal Entity Reference Data – LE-RD) and Level 2 data (Relationship Data)
• All challenges submitted by eligible parties, regardless of whether they are the LEI holder or an unrelated stakeholder

This policy outlines:

• The types of data that can be challenged
• Who may raise a challenge
• How challenges may be submitted
• The evidence required
• Resolution timelines and escalation mechanisms

The aim is to uphold data quality, accuracy, and user confidence in the LEI system while maintaining compliance with global and jurisdictional data governance standards.

Clause 2: Definitions

For the purpose of this Policy, the following definitions apply:

• LEI (Legal Entity Identifier): A 20-character alphanumeric code that uniquely identifies a legally distinct entity that engages in financial transactions, governed by ISO 17442.
• LE-RD (Legal Entity Reference Data): Publicly available information associated with an LEI, including the entity’s name, legal form, address, registration details, and status.
• Level 2 Data (Relationship Data): Information identifying the direct and ultimate parent(s) of a legal entity or the applicable exception if the parent cannot be disclosed.
• GLEIF: The Global Legal Entity Identifier Foundation, the oversight body coordinating LEI issuance and data quality worldwide.
• Challenge: A formal request by any stakeholder to review and potentially correct data associated with an LEI.
• Challenger: A natural or legal person who submits a challenge under this policy.
• Candidate LOU: A Legal Entity Identifier Issuer in the process of obtaining full accreditation from GLEIF.
• Authoritative Source: An official or credible registry, financial document, or declaration used to validate LEI data.
• Challenge Resolution: The process by which TNV-LEI investigates and responds to a submitted challenge.
• GLEIF Challenge Portal: An online interface maintained by GLEIF allowing global stakeholders to initiate challenges directly via the LEI search tool.

Clause 3: Who Can Submit a Challenge

TNV-LEI permits any individual or legal entity to submit a challenge against any LEI record under its management. This open policy ensures that data quality can be collaboratively improved, reflecting the transparency objectives of the Global Legal Entity Identifier System (GLEIS).

The following parties are eligible to submit a challenge:

• Legal Entity (LEI Holder): The entity to which the LEI has been issued.
• Third Parties: Any external person, organization, or data user who identifies an error in LEI data.
• Regulatory Bodies and Authorities: Supervisory, tax, and financial authorities with regulatory oversight.
• GLEIF or Other LOUs: In cases where inter-LOU cooperation is necessary.
• Public Stakeholders: Journalists, analysts, academics, or any member of the public.

No prior relationship with the LEI holder is required to initiate a challenge. TNV-LEI supports GLEIF’s commitment to public validation of data integrity, and therefore ensures that all valid challenge submissions are received, assessed, and responded to without prejudice.

Clause 4: What Can Be Challenged

TNV-LEI permits challenges on any factual inaccuracies, outdated entries, or unsupported declarations in the Legal Entity Identifier (LEI) record. This includes both Level 1 (Legal Entity Reference Data) and Level 2 (Parent Relationship Data), as defined by GLEIF and ISO 17442.

The following aspects of an LEI record may be challenged:

1. Entity Identification Data (Level 1):

   • Legal name or legal form of the entity
   • Registered address or head office address
   • Registration number or business registry reference
   • Entity status (active/inactive, merged, dissolved)

2. Parent Relationship Data (Level 2):

   • Direct and ultimate parent LEIs
   • Relationship type and accounting consolidation status
   • Incorrect exception declarations (e.g., "no known parent")

3. LEI Status and Duplicates:

   • Duplicate LEIs issued to the same entity
   • LEIs issued to ineligible entities
   • Incorrectly lapsed or retired status

4. Publication or Display Errors:

   • Incorrect mapping of data on TNV-LEI or GLEIF directories

All challenges must be based on credible and verifiable information and are subject to review by TNV-LEI. TNV-LEI reserves the right to reject frivolous or malicious challenges.

Clause 5: Submission Channels

TNV-LEI offers the following channels for submitting challenges:

1. Online via TNV-LEI Portal:

   • Visit www.tnvlei.com
   • Use the designated “Challenge LEI” feature or support submission form

2. By Email:

   • Email your challenge to: challenge@tnvlei.com
   • Include the LEI number, the data in question, and supporting documentation

3. Via GLEIF Global Challenge Portal:

   • Visit www.gleif.org
   • Use the LEI search tool
   • Select the LEI and click “Challenge this LEI”
   • Follow the instructions

Challengers must provide clear explanations and attach authoritative evidence in supported formats (PDF, DOCX, JPEG, etc.). Anonymous submissions are not accepted.

Clause 6: Evidence Requirements

All challenge submissions must be supported by reliable and verifiable evidence. TNV-LEI relies on authoritative documentation to confirm the validity of any requested data change.

6.1 Accepted Forms of Evidence:

• Official registry extracts or government records (e.g., Ministry of Corporate Affairs, SEC filings)
• Certified copies of incorporation or business registration documents
• Audited financial statements, particularly for parent relationship validation
• Court orders or legal notices
• Board resolutions or corporate disclosures
• Any other publicly accessible and verifiable document

6.2 Requirements for Documentary Evidence:

• Must be in English or accompanied by a certified English translation
• Must match the legal name, registration number, or LEI under challenge
• Must clearly support the correction requested

TNV-LEI reserves the right to contact the LEI holder or related parties for further clarification if required. Challenges without sufficient or relevant documentation may be closed without modification.

Clause 7: Handling Process

Once a challenge is submitted through the designated TNV-LEI channel, the following process is followed:

1. Acknowledgment of Receipt:

   • TNV-LEI will acknowledge receipt of the challenge via email within 3 business days.

2. Initial Review and Verification:

   • The challenge will be reviewed for completeness and validity, including:
     • Clarity of the issue raised
     • Presence of required supporting documentation
     • Whether the subject LEI is managed by TNV-LEI

3. Assignment to Validation Team:

   • A designated Challenge Resolution Officer or validation expert will be assigned to investigate and handle the challenge.

4. Contact with Stakeholders (if needed):

   • TNV-LEI may reach out to the LEI holder or related parties to:
     • Verify facts
     • Obtain clarification
     • Request additional supporting documents

5. Decision and Outcome:

   • Based on the evidence and findings:
     • If the challenge is upheld, the LEI record will be updated and republished.
     • If the challenge is rejected, the challenger will be informed of the reason in writing.

6. Documentation and Recordkeeping:

   • All challenge cases and outcomes will be documented and maintained as part of TNV-LEI’s audit trail.

7. Publication of Updated Data:

   • If applicable, corrected LEI records will be uploaded to GLEIF and made publicly available via the TNV-LEI and GLEIF databases.

TNV-LEI ensures that all challenges are treated objectively, confidentially, and without undue delay. Complex or disputed cases may require extended time for proper investigation.

Clause 8: Timeframes for Acknowledgment and Resolution

TNV-LEI is committed to processing all valid challenges in a timely and efficient manner while maintaining accuracy and transparency. The following timeframes shall apply:

1. Acknowledgment of Challenge

   • TNV-LEI will acknowledge receipt of the challenge via email within 3 business days of submission.

2. Assessment and Investigation Period

   • TNV-LEI will complete the initial review and validation process within 15 calendar days from the date of acknowledgment.

3. Extension for Complex Cases

   • If the challenge involves complex documentation, jurisdictional verifications, or third-party coordination, TNV-LEI may extend the resolution timeline. In such cases:
     • The challenger will be notified with an estimated revised timeline
     • Progress will be communicated every 10 business days until closure

4. Closure Notification

   • Once resolved, TNV-LEI will issue a formal outcome to the challenger by email, indicating:
     • Whether the challenge was accepted or rejected
     • Summary of action taken or justification for rejection

5. GLEIF Reporting

   • Any changes resulting from a successful challenge will be published in the TNV-LEI records and reflected in the GLEIF database in the next scheduled update cycle.

TNV-LEI strives to uphold the GLEIF-recommended 15-day challenge resolution benchmark, ensuring responsiveness and data integrity across the LEI ecosystem.

Clause 9: Re-submission and Review Rights

TNV-LEI recognizes the right of every challenger to seek reconsideration or provide additional evidence if a previously submitted challenge is closed without modification. The following provisions govern re-submission:

1. Eligibility to Re-submit

   • Any challenger whose original challenge was rejected or deemed inconclusive may submit a follow-up challenge.

2. Conditions for Re-submission

   • The re-submission must:
     • Refer to the original challenge reference number
     • Provide new, material, or clarifying evidence not included in the initial challenge
     • Clearly explain the grounds for reconsideration

3. Timeframe for Re-submission

   • Re-submission must be made within 28 calendar days of receiving the outcome of the original challenge.

4. Evaluation of Re-submission

   • TNV-LEI will treat the re-submitted challenge as a new case but linked to the prior record.
   • A fresh review will be conducted with attention to the new evidence provided.

5. Record Linking and Traceability

   • TNV-LEI will maintain a traceable audit trail linking the original and re-submitted challenges for transparency and auditability.

6. Final Decision Communication

   • The decision on the re-submission will be communicated within the standard challenge timeframe unless otherwise notified.

TNV-LEI is committed to fair and reasonable data governance practices and ensures that legitimate concerns are reconsidered in light of additional supporting information.

Clause 10: Escalation to GLEIF

If a challenger is not satisfied with the resolution or response provided by TNV-LEI regarding a submitted challenge, the matter may be escalated to the Global Legal Entity Identifier Foundation (GLEIF) using their official LEI Challenge Portal.

1. Right to Escalate

   • Escalation is available to any challenger who believes:
     • The challenge was not adequately addressed
     • The LEI data remains factually incorrect
     • The outcome contradicts publicly verifiable information

2. How to Escalate to GLEIF

   • Visit the GLEIF LEI Search Tool
   • Locate the specific LEI record in question
   • Click the “Challenge this LEI” option and follow the submission process

3. Supporting Evidence Required

   • GLEIF expects challengers to provide:
     • A clear explanation of the issue
     • Supporting documentation in English (or certified English translation)
     • Reference to previous challenge attempts with TNV-LEI (if applicable)

4. GLEIF’s Review Process

   • GLEIF will assess the challenge independently and coordinate with TNV-LEI if needed
   • If the challenge is deemed valid, TNV-LEI will be required to update the LEI record accordingly

5. Transparency and Follow-up

   • GLEIF may communicate the resolution outcome to both TNV-LEI and the challenger
   • TNV-LEI will make necessary updates to the record as per GLEIF instruction

Challengers are encouraged to exhaust the internal TNV-LEI challenge process before escalating. TNV-LEI remains committed to cooperating fully and transparently with GLEIF on all escalated challenges.

Clause 11: Data Transparency

TNV-LEI upholds the principle of open access and public transparency in the LEI ecosystem, as defined by the Global Legal Entity Identifier Foundation (GLEIF). All LEI records and their associated challenge history (where applicable) are made publicly available in compliance with ISO 17442 and GLEIF contractual obligations.

1. Public Disclosure of LEI Data

   • All active, lapsed, merged, and retired LEIs, along with their Legal Entity Reference Data (LE-RD) and Relationship Data, are published and accessible via:
     • The TNV-LEI portal: www.tnvlei.com
     • The GLEIF LEI database: www.gleif.org

2. Publication of Updates Post-Challenge

   • If a challenge results in data modification:
     • The corrected record is published in TNV-LEI’s Delta and Full LEI files
     • The updated record is synchronized with GLEIF in the next scheduled update

3. Record of Challenge Activity

   • TNV-LEI maintains internal records of challenge submissions, decisions, and updates
   • While the content of individual challenges is not made public, the resulting changes to the LEI record are publicly reflected

4. GLEIF Open Data Charter Compliance

   • TNV-LEI adheres to the GLEIF Open Data Charter and CC0 license standards for the reuse and redistribution of LEI content without restriction

This commitment to transparency ensures stakeholder confidence in the LEI system and enables regulators, financial institutions, and the public to rely on the integrity of entity identification data.

Clause 12: Record Keeping & Documentation

TNV-LEI ensures that all challenge submissions and related communications are documented and securely retained to support auditability, transparency, and regulatory compliance.

1. Challenge Register

   • TNV-LEI maintains a centralized Challenge Register documenting:
     • Date of submission
     • LEI under challenge
     • Type of data challenged
     • Resolution outcome
     • Date of closure

2. Retention Period

   • All challenge-related records (including correspondence, supporting evidence, and resolution logs) shall be retained for a minimum of 8 years from the date of resolution, or longer if required by law or GLEIF guidelines.

3. Confidentiality and Access Control

   • All challenge files are stored securely in TNV-LEI’s document management system with access limited to authorized personnel only.
   • Personally identifiable information (PII), if collected during the challenge process, is handled in accordance with TNV-LEI’s Privacy Policy and DPDP Act requirements.

4. Version Control and Auditability

   • All updates, re-submissions, and clarifications are versioned and time-stamped to maintain traceability.
   • Audit trails are available for internal and external audits, including those initiated by GLEIF.

5. Linked Records and GLEIF Notifications

   • In cases where challenges result in changes to the LEI, the updated LEI record is linked to the original challenge case internally.
   • TNV-LEI may submit summary data of challenge outcomes to GLEIF for monitoring purposes.

Through this policy, TNV-LEI promotes accountability and systematic documentation to ensure the integrity of the LEI Challenge Management framework.

Clause 13: Review and Maintenance

TNV-LEI is committed to maintaining an up-to-date and effective Challenge Policy that reflects changes in GLEIF guidance, applicable laws, and operational best practices.

1. Annual Review

   • This policy shall be formally reviewed by the Compliance Officer at least once every 12 months to ensure relevance and alignment with the latest GLEIF Challenge Manual and ISO 17442 updates.

2. Trigger-Based Updates

   • The policy may also be updated:
     • Upon issuance of new GLEIF challenge requirements
     • Following internal audits or GLEIF assessments
     • In response to user feedback or system improvements

3. Version Control

   • All updates to the policy will be version-controlled, with an effective date and change history recorded at the end of the document.
   • Archived versions will be retained for a period of 8 years.

4. Publication and Communication

   • The latest version of this Challenge Policy will be published at www.tnvlei.com/legal and will be available for download by any stakeholder.
   • Clients and users may be notified via system updates, bulletins, or direct email when material changes are made.

This clause ensures the Challenge Policy remains a living and responsive document that evolves with regulatory, technical, and stakeholder needs.

Clause 14: Contact Information

For inquiries, support, or to submit a challenge related to LEI records managed by TNV-LEI, stakeholders may use the following contact details:

1. Primary Challenge Submission Contact

   • Email: challenge@tnvlei.com

2. Mailing Address: LEI International Pvt. Ltd. (TNV-LEI) TNV House, B-1/19/69, Sector-K Aliganj, Lucknow – 226024 Uttar Pradesh, India

3. Grievance Officer (for unresolved concerns):

• Designation: Grievance Officer
• Email: grievance@tnvlei.com

4. Website & Online Forms

• Visit: www.tnvlei.com → Support or Legal section

TNV-LEI strives to maintain open and responsive communication with its users and stakeholders. Feedback and suggestions on this policy are also welcome.