7.1  Funds relationships in the global LEI system: LEI ROC consultation

On 27 September 2017, the Legal Entity Identifier (LEI) Regulatory Oversight Committee (LEI ROC) - published a consultation paper on funds relationships in the global LEI system (GLEIS).

The consultation paper proposes a limited update to the way relationships affecting investment funds or collective investment schemes are recorded in the GLEIS, by replacing the current single fund family relationship with four relationships that would be recorded as part of relationship data:

  • fund management entity;
  • umbrella fund;
  • master-feeder; and
  • other fund family.

The consultation paper also discusses and seeks views on whether an entity that has a relationship with a fund should always be reported to the GLEIS using the LEI of this entity (which would in practice, force such related entities to obtain an LEI, even where they are not required to do so by the law or regulation of the jurisdiction where they are organised and/or do business), or whether the current situation where a name is recorded could be continued, as well as other issues such as the validation and recording of these relationships.

Comments are requested by 26 November 2017. These will be used to inform the final version of the policy framework that the LEI ROC will approve for implementation by the Global LEI Foundation. Implementation will not take place before January 2019.