May 20, 2019

LEI ROC published its final policy on fund relationships in the Global Legal Entity Identifier System (GLEIS), along with guidelines for the registration of investment funds in the GLEIS. The report provides definitions of relationships affecting investment funds or collective investment schemes ("Fund Management Entity," "Umbrella Fund," and "Master-Feeder") and specifies when reporting these relationships would be optional. Implementation is expected within eighteen months of the publication of this policy.

The eighteen months are needed for the implementation, given the need for GLEIF to prepare the technical standards in consultation with the Local Operating Units (LOUs), for LOUs to implement them and provide sufficient guidance to registrants ahead of implementation. The policy report explains the objectives of the data collection and details why the rules of GLEIS should require a fund to report the LEI as opposed to only the name of the related entity. It also explains why, following the public consultation, the continuation of an optional approach has been adopted by LEI ROC, with some exceptions. The policy describes how these relationships should be verified, lists issues to consider when representing fund relationships in the GLEIS, and discusses the future work on other fund relationships.

The report offers a limited update to the way relationships affecting investment funds are recorded in GLEIS, with the aim to ensure that the implementation of relationship data is consistent throughout the GLEIS and to provide a way to facilitate the standardized collection of fund-relationship information at the global level. This is being done by providing definition for fund relationship and aligning the data structure with what is done for direct and ultimate accounting parent entities as defined in LEI ROC report of March 2016. The report asks GLEIF to replace the current optional reporting of a single “fund family” relationship as part of Level 1 (reference data of the entity) with certain relationships as part of “Level 2” data (relationship data). In line with responses to the first consultation, LEI ROC adopted eliminating the proposed generic category “Other Fund Family” (except for past records) and not including any additional relationships at this stage. LEI ROC adopted that the collection of these relationships in the GLEIS will 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
  • For the relationship between an umbrella structure and a sub-fund or compartment or other sub-structure

 

Effective Date: Policy Report+18 Months

Keywords: International, Banking, Securities, Fund Relationships, GLEIS, GLEIF, LEI, LEIROC

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