MFA Submits Joint Response to LEI Consultation on Fund Relationship Data

December 01, 2017

From: MFA, SIFMA AMG, IAA and the ICI

To:

Legal Entity Identifier Regulatory Oversight Committee

Today, MFA submitted a joint comment letter with SIFMA’s Asset Management Group (SIFMA AMG), the Investment Adviser Association (IAA), and the Investment Company Institute (ICI) in response to the LEI Regulatory Oversight Committee (ROC)’s consultation.  This consultation proposes to require additional fund relationship data in order to obtain or renew a Legal Entity Identifier (LEI).

The LEI ROC Working Group, comprised of a number of European regulators and the SEC, developed the proposal to improve the way funds relationships are recorded and to understand the interconnectedness of funds for monitoring market conduct, potential systemic risks, and risk aggregation.

In the letter, the Associations express significant concerns with the proposed fund relationship requirements.  The Associations believe that mandating such requirements would impose unjustified operational and cost burdens on funds and their managers to obtain and renew LEIs.  The relative ease in obtaining an LEI, which is now necessary in a number of key jurisdictions in order to trade, should not be undermined by adding more complexity at this time.

The Associations recommend further study of this topic by the LEI ROC.

Please contact Laura Harper Powell with any questions.

Joint Buy Side Associations Comment Letter re LEI Fund Relationships Consultation (Dec 1 2017)

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