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MFA – SIFMA AMG – ISDA Joint Comment Letter on LEI ROC Fund Relationships Second Consultation

MFA, SIFMA AMG, and ISDA submitted a joint response letter and related comment questionnaire to the LEI Regulatory Oversight Committee (LEI ROC) in response to its second consultation on fund relationships in the Global LEI System.

The letter expresses support for the LEI ROC’s positive proposals in response to industry comments:

• Eliminate the proposed generic category of “Other Fund Family”;
• Make the collection of “Fund Management Entity,” “Umbrella Structures” and “Master-Feeder” relationships in the GLEIS optional, with two exceptions: 1) 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; 2) if the relationship is between an umbrella structure and a sub-fund or compartment.

Click here to download the letter

Click here to download the questionnaire.