On November 19, the Legal Entity Identifier Regulatory Oversight Committee (LEI ROC) published its second consultation paper on fund relationships in the Global Legal Entity Identifier System (GLEIS).

In its second consultation paper, LEI ROC explains that a significant proportion of entities that have a legal entity identifier (LEI) are investment funds. Consequently, LEI ROC proposes a limited update to the way relationships affecting funds are recorded in the GLEIS. The update aims to ensure that the implementation of relationship data is consistent throughout the GLEIS and to provide a means to facilitate a standardized collection of fund relationship information at the global level.

LEI ROC proposes to achieve its objectives by:

  1. providing a definition for each fund relationship; and
  2. improving the alignment of the data structure with what is done for direct and ultimate accounting parent entities (as defined in its report of March 10, 2016).

LEI ROC also has published draft guidelines for consultation, in Annex 1 of the second consultation, for the registration of investment funds in the GLEIS. This is to improve the quality of information on funds by addressing the drawback that relationship data would not be available in all cases.

The second consultation includes a summary of responses to LEI ROC’s first consultation regarding improvements to definitions such as “Fund Management Entity,” “Master Feeder” and “Umbrella Funds.”

The deadline for submitting comments on the proposals is January 14, 2019. Responses received to the second consultation will inform the final version of the policy framework that the LEI ROC will approve for implementation by the Global LEI Foundation, which will not take place before January 2020.

The first consultation paper is available here and second consultation paper is available here.

The report of March 10, 2016 is available here.