On 19 November 2018, the Legal Entity Identifier Regulatory Oversight Committee (LEI ROC) published its second consultation paper on fund relationships in the global LEI system. The consultation paper provides a limited update to the way relationships affecting funds are recorded in the Global LEI System (GLEIS). To ensure consistency throughout the GLEIS, the consultation paper proposes: (i) providing a definition for each fund relationship; and (ii) better aligning the data structure with what is done for direct and ultimate accounting parent entities as defined in the LEI ROC report of March 2016.

Specifically, the consultation paper proposes that the current optional reporting of a single ‘fund family’ relationship as part of level 1 data be replaced with the following relationships as part of level 2 data: Fund Management Entity relationship; Umbrella Structures relationship; and Master-Feeder relationship. The current ‘Other fund family’ is further recommended to be removed.

The LEI ROC proposes that the collection of these relationships in the GLEIS would be optional, except:

  • if the relationship is mandated to be reported and publicly available in the relevant jurisdiction and if the LEI is mandatory for the related entity in the relevant jurisdiction; and / or
  • for the relationship between an umbrella structure and a sub-fund or compartment.

The deadline for responses to the consultation paper is 14 January 2019. The final framework that the LEI ROC is consulting on will not be implemented before January 2020.