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LEI ROC Consults on Fund Relationships in GLEIS

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.

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume VIII, Number 334


About this Author

John Ahern, Financial Attorney, London, Katten Law Firm

John Ahern, partner at Katten Muchin Rosenman UK LLP and head of the London Financial Services group, focuses his practice on banking, financial services, UK and European financial markets, and related regulations. His background in private practice and as in-house counsel at a global investment bank provides him with perspective on the unique regulatory issues facing the wholesale and private banking sectors. John advises multilateral trading facilities, broker-dealers and banks on trading, clearing and settlement as well as custody of securities—both physical and...

+44 (0) 20 7770 5253
Carolyn H. Jackson, International Attorney, Katten Muchin law firm

Carolyn Jackson is a partner in Katten Muchin Rosenman UK LLP and is a Registered Foreign Lawyer. She provides US financial regulatory legal advice to a broad range of market participants, including commercial banks, investment banks, investment managers, broker-dealers, electronic trading platforms, clearinghouses, trade associations and over-the-counter derivatives service providers.

Carolyn guides clients in the structuring and offering of complex securities, commodities and derivatives transactions and in complying with US securities and commodities laws and regulations. 

+44 0 20 7776 7625
Nathaniel Lalone, Katten Muchin Law Firm, Financial Institutions Attorney
Senior Associate

Nathaniel Lalone, a partner at Katten Muchin Rosenman UK LLP, has a broad range of experience in the regulation of financial products and financial markets, and frequently provides regulatory and compliance advice to trading venues, clearing houses and buy-side firms active in the over-the-counter (OTC) derivatives, futures and securities markets. He is actively involved in advising clients on the implementation of MiFID 2 and MiFIR in the European Union as well as the international reach of US financial services regulation. He also has significant experience with structuring...

+44 0 20 7776 7629
Neil Robson, private equity fund managers counselor, Katten Law Firm, London

Neil Robson, a regulatory and compliance partner with Katten Muchin Rosenman LLP, focuses his practice on counseling hedge and private equity fund managers and other investment advisers on operational, regulatory and compliance issues. He regularly addresses Financial Conduct Authority (FCA) and EU authorization and compliance under both the EU Alternative Investment Fund Managers Directive (AIFM Directive) and MiFID, cross-border issues in the financial services sector, market abuse, anti-money laundering and regulatory capital requirements, formations and buyouts of...