Scout Alert! FERC and Commenters Agree — DUNS Numbers Insufficient


Yesterday I got a Scout alert, notifying me of a proposed rule change by the Federal Energy Regulatory Commission (FERC) in how electric utilities report their prices. The major rule change isn’t of major concern to me, but it did include a passage that I found interesting:

However, DUNS numbers have proven to be an imprecise identification system, as entities may have multiple DUNS numbers, only one DUNS number, or no DUNS number at all. The Commission has considered various alternatives to the use of DUNS numbers, but finds none of the suggested approaches would provide a viable replacement. Accordingly, the Commission will continue to rely on the insertion of customer company names in the free-form fields, Field Numbers 16 and 48. In this regard, however, the Commission finds reasonable Entergy’s suggestion to require reporting of the name of the entity exactly as it appears on the reported contract, in both the contract and transaction sections.

The Commission’s comments clearly summarize why the government’s reliance on DUNS numbers for entity identification is problematic. This comes in the wake of a GAO report that came to very similar conclusions but explored the problems with DUNS numbers from a federal spending perspective. The GAO report also discussed the problems with the restrictions on the reuse of DUNS numbers, as well as their considerable expense ($154 million over three years).

Most notably though, the Commission notes the lack of a feasible alternative. It’s true that an ideal alternative might not be available quite yet, but matching based on name alone is one of the least reliable ways of crosswalking company data. At the very least, the commission could require that the entity’s home jurisdiction of incorporation (usually a state) and related number be reported. This would allow the data to be linked to company data in OpenCorporates or to the state registries.

Thankfully, more and more agencies and organizations are realizing the far reaching consequences of not having a reliable and unique entity identifier. We even saw a provision in the House version of the DATA act that required the use of non-proprietary identifiers for recipients in federal spending data. Unfortunately, this provision has not made it to the Senate version. We hope that this provision makes it into the final version of the DATA Act, spurring some movement forward on an issue that underpins so many areas of our concern here at Sunlight.