Data Challenge User Guide

Clause 1: Purpose and Applicability

The purpose of this User Guide is to help clients, agents, and public stakeholders understand how to initiate a valid challenge when a Legal Entity Identifier (LEI) record appears incorrect or outdated.

This document outlines the process, platforms, and rules for submitting a challenge in compliance with the Global Legal Entity Identifier Foundation (GLEIF) Challenge Manual (v1.3) and TNV-LEI procedures.

This guide applies to the following scenarios:

1. Self-managed Updates:

   • If you are a TNV-LEI client or an authorized representative (e.g., director, employee, or client agent), you may:
     • Log in to the TNV-LEI portal
     • Access your account and directly update your LEI data (e.g., name, address, registration number)
     • No formal challenge is required in this case

2. Public or Third-Party Challenge:

   • If you observe incorrect LEI data of another entity (not under your control), you may:
     • Submit a formal LEI Challenge via:
       • GLEIF LEI Search Tool (https://search.gleif.org)
       • TNV-LEI challenge form or support channel (if the LEI is managed by TNV-LEI)
     • TNV-LEI will then verify the data with the LEI holder and decide if an update is warranted

3. Management Scope and Routing Guidance:

   • TNV-LEI will only accept and act upon challenges concerning LEIs that are currently managed by TNV-LEI
   • If the LEI in question is managed by another LOU, you should:
     • Challenge it directly with the respective LOU, or
     • Use the global GLEIF challenge portal to initiate the process
   • If you are unsure which LOU manages a specific LEI, visit GLEIF LEI Search to find the managing LOU and access their challenge facility

This process ensures:

• Accurate, publicly available LEI data
• Appropriate routing of corrections based on user role and LOU scope
• Efficient handling of entity-managed updates versus public challenge submissions

Clause 2: Definitions and References

This section defines key terms and documents referenced throughout the Challenge Process User Guide to ensure clarity and consistency.

1. Legal Entity Identifier (LEI):

   • A 20-character alphanumeric code that uniquely identifies legally distinct entities that engage in financial transactions, issued according to ISO 17442.

2. Legal Entity Reference Data (LE-RD):

   • Publicly available entity-level information linked to an LEI, including legal name, registered address, registration ID, legal form, and entity status.

3. Relationship Data (Level 2 Data):

   • Information pertaining to a legal entity’s direct and ultimate parent relationships, including exceptions where parent information is not disclosed.

4. Challenge:

   • A formal request initiated by any stakeholder to correct, update, or verify LEI data where inaccuracies or omissions are identified.

5. Challenger:

   • A person or entity that submits a challenge. This includes LEI holders, regulators, agents, competitors, researchers, or the public.

6. Local Operating Unit (LOU):

   • An organization accredited by GLEIF to issue and manage LEIs within the Global LEI System. TNV-LEI is currently a Candidate LOU (GLEIF ID: 9269).

7. Candidate LOU:

   • A legal entity that has entered the GLEIF accreditation process and may perform LEI issuance and related activities pending full accreditation.

8. GLEIF (Global Legal Entity Identifier Foundation):

   • The global authority overseeing the implementation, integrity, and use of the LEI system. Website: www.gleif.org

9. GLEIF Challenge Manual:

   • A procedural document published by GLEIF that outlines rules, methods, and standards for submitting and resolving LEI data challenges. Current version: v1.3 (January 2025).

10. GLEIF LEI Search Tool:

    • An online platform available at https://search.gleif.org that allows users to search LEI records and initiate challenges.

Clause 3: Document Control

This User Guide is a controlled document maintained by TNV-LEI to ensure that the procedure for submitting and processing LEI data challenges remains aligned with current GLEIF requirements and internal governance protocols.

• Document Title: LEI Challenge Process – User Guide
• Document Code: TNV-LEI/PROC/CHAL/UG
• Version: 1.0
• Effective Date: April 2025
• Approval Authority: Chief Compliance Officer, TNV-LEI
• Review Cycle: Annually or upon significant procedural or regulatory changes

Change History

The current version of this document shall be published on the official TNV-LEI portal under www.tnvlei.com/legal and be made available for all clients, stakeholders, and regulators as needed.

Clause 4: Step-by-Step Guide to Initiating a Challenge

This section provides a step-by-step walkthrough to help users raise a challenge for correcting LEI data through either the GLEIF Challenge Portal or TNV-LEI's support channels, depending on the managing LOU.

4.1 Via GLEIF Challenge Portal (for any LEI)

1. Go to https://search.gleif.org
2. Search the LEI or Legal Entity Name
3. Select the correct record from the search results
4. Click the “Challenge this LEI” button
5. Log in or register with a valid email address
6. Choose the appropriate challenge category (e.g., Reference Data, Relationship Data)
7. Enter the corrected value and upload supporting documentation
8. Submit the challenge and receive a confirmation with tracking ID

4.2 Via TNV-LEI Portal (only for LEIs managed by TNV-LEI)

1. Visit www.tnvlei.com
2. Navigate to the Support or Challenge section
3. Complete the challenge form with all necessary fields
4. Upload supporting documents
5. Submit via web or email to challenge@tnvlei.com
6. Await acknowledgment from TNV-LEI within 3 business days

📌 Note: If the LEI is not managed by TNV-LEI, users are advised to submit the challenge directly through the GLEIF Challenge Portal or the respective LOU’s portal.
This two-path approach ensures that challenges are properly routed and resolved under the correct authority.

Clause 5: Challenge Categories (Tabs/Types)

GLEIF provides a structured set of challenge categories, also known as “tabs,” to classify and process LEI data challenges efficiently. TNV-LEI aligns with these categories to ensure a consistent and standardized resolution process.

5.1 Update Reference Data

Used to correct Level 1 (Legal Entity Reference Data) such as:

• Legal name of the entity
• Legal form
• Registration authority and registration number
• Legal or head office address
• Entity status (e.g., active, inactive, merged, closed)

5.2 Update Relationship Data

Used to challenge Level 2 (Parent Relationship Data) involving:

• Direct or ultimate parent LEIs
• Consolidation status or exception reason
• Incorrect relationship disclosures or missing parent records

5.3 Entity Events

Used to notify structural or operational changes to the entity:

• Mergers, acquisitions, or demergers
• Dissolution or liquidation
• Any other material change affecting the LEI status

5.4 Challenge LEI Code

Used to flag issues with the LEI code itself:

• Duplicate LEIs assigned to the same entity
• LEI wrongly attributed or assigned
• Invalid or obsolete LEI references

5.5 Challenge vLEI Credential (if applicable)

Used to raise concerns about the digital credential:

• Role misrepresentation in a verifiable LEI (vLEI)
• Misuse of vLEI for impersonation or unauthorized validation

📌 Note: Selecting the correct category helps reduce processing time and increases the likelihood of a swift resolution.

Clause 6: Providing Corrected Information and Uploading Evidence

Submitting a challenge requires not only identifying the incorrect information but also proposing the correct value and supplying evidence that supports the claim. TNV-LEI encourages detailed, verifiable submissions to ensure efficient validation and resolution.

6.1 Providing New or Corrected Values

• Each field being challenged must include the corrected or proposed new value
• Clearly identify the section of the LEI data (Reference or Relationship Data)
• Avoid ambiguity; use official spellings and registered names where applicable

6.2 Adding Comments or Explanatory Notes

• Optional but recommended: briefly explain the nature of the discrepancy
• If relevant, provide context such as a recent company restructuring, merger, or registry update

6.3 Uploading Supporting Evidence

• Accepted Formats: PDF, JPEG, PNG, DOCX, XLSX
• File Size Limit: Maximum 10 MB per file

Supporting documentation should:

• Be issued by an authoritative source (e.g., registrar of companies, financial regulator)
• Be current and consistent with the data you are challenging
• Be in English or accompanied by a certified English translation
• Multiple documents can be uploaded if needed

📌 Supporting documentation is essential. TNV-LEI may reject challenges lacking sufficient or clear evidence. Incomplete submissions lead to delays or closure without action.

Clause 7: Review, Submit & Tracking Your Challenge

Before submitting a challenge, it is essential to review the entries carefully to ensure accuracy, completeness, and traceability. Once submitted, TNV-LEI or GLEIF (depending on the channel used) will acknowledge and assign a tracking reference.

7.1 Final Review Before Submission

• Ensure that all fields have been filled accurately
• Verify that all supporting documents are properly attached and legible
• Confirm that the corrected values align with the uploaded documentation

7.2 Submission Confirmation

• Click the Submit button on the portal or submit via email to challenge@tnvlei.com
• You will receive a confirmation message and a unique challenge reference ID via email

7.3 Tracking Your Challenge

• Retain the reference ID for future communication
• You may check the status:
  • Via GLEIF’s portal (if challenge was submitted there)
  • By contacting TNV-LEI support team with the reference number

📌 Tip: Prompt responses to any clarification emails from TNV-LEI help avoid delays in processing.

Clause 8: Communication, Clarification & TNV-LEI Review

Once a challenge is submitted, TNV-LEI will begin the internal validation and verification process based on the information and evidence provided. Communication is central to this review stage.

8.1 Acknowledgment of Receipt

• TNV-LEI will acknowledge every valid challenge submission via email within 3 business days
• The acknowledgment will include the reference ID and basic instructions for future communication

8.2 Request for Clarification or Additional Information

• If submitted documentation is unclear, incomplete, or insufficient:
  • TNV-LEI will request further details or revised evidence
  • A deadline (usually 7 calendar days) will be provided for response

8.3 Internal Review and Assessment

• A Challenge Resolution Officer will:
  • Cross-verify the submitted data with authoritative sources
  • Assess compliance with GLEIF standards and TNV-LEI data governance rules
  • Liaise with the legal entity (if applicable) for additional confirmation

8.4 Decision and Closure

• TNV-LEI will inform the challenger of the outcome:
  • Accepted – LEI record will be updated and published accordingly
  • Rejected – Justification will be provided
• All responses will be sent via official communication channels, typically by email

📌 All communication is recorded and audit-traceable. TNV-LEI ensures impartial, timely, and professional handling of each challenge.

Clause 9: Re-submission and Escalation Options

If a challenge has been closed without correction and the challenger believes the outcome was incorrect or insufficient, they have the right to re-submit or escalate the case as per the following:

9.1 Re-submission to TNV-LEI

• A challenge may be re-submitted within 28 calendar days of closure
• The re-submission must include:
  • The reference number of the original challenge
  • New or supplementary evidence not presented earlier
  • Clear explanation of why the outcome is disputed

📌 Re-submissions with identical information and no new justification are likely to be closed without further action.

9.2 Escalation to GLEIF

• If the re-submission is also closed or if the LEI is managed by another LOU:
  • The case may be escalated to GLEIF through the Global Challenge Portal
  • Visit: https://search.gleif.org
  • Locate the relevant LEI and click “Challenge this LEI” to initiate the process

9.3 GLEIF Review and Resolution

• GLEIF will review the case independently and may:
  • Request TNV-LEI (or other LOUs) to investigate further
  • Instruct the LOU to make necessary updates if the challenge is deemed valid

TNV-LEI fully cooperates with GLEIF during escalated reviews and ensures fair handling of all valid concerns in accordance with the GLEIS governance model.

Clause 10: Support & Contact Information

If you require assistance, clarification, or encounter issues while submitting a challenge, please reach out to TNV-LEI through the following support channels:

10.1 Challenge Submissions and Technical Support

• Email: challenge@tnvlei.com
• Portal: www.tnvlei.com → Navigate to Support / Challenge Section
• Working Hours: Monday to Friday, 10:00 AM – 6:00 PM IST (Excluding Public Holidays)

10.2 Grievance Handling

• Grievance Officer: grievance@tnvlei.com
• TNV-LEI is committed to resolving formal complaints within 30 calendar days from the date of receipt

10.3 External Escalation (GLEIF)

• GLEIF Website: www.gleif.org
• LEI Search and Challenge Tool: https://search.gleif.org

10.4 Mailing Address

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

For templates, help guides, and detailed policy documents, visit: www.tnvlei.com/legal