January 18, 2019

Via Email ([email protected])
Legal Entity Identifier Regulatory Oversight Committee

Re: Second Consultation Document on Fund Relationships in the Global LEI System

Dear Sirs and Madams:

The Securities Industry and Financial Markets Association’s Asset Management Group (“SIFMA AMG” or “AMG”), Managed Funds Association (“MFA”) and International Swaps and Derivatives Association, Inc. (“ISDA”) (together the “Associations”) appreciate the opportunity to provide feedback to the Legal Entity Identifier Regulatory Oversight Committee (“LEI ROC”) regarding its Second Consultation Document on Fund Relationships in the Global LEI System (the “Consultation”). The Consultation proposes a limited update to the way relationships affecting funds are recorded in the Global LEI System (the “GLEIS”) and to replace the current optional single “fund family” relationship as part of Level 1 (reference data of the entity) with the following relationships as part of Level 2 data (relationship data): “Fund Management Entity”, “Umbrella Structures”, and “Master-Feeder” relationship.

We commend the LEI ROC’s outreach to the industry and the effort to ensure that the design of the fund relationship data is clear and meaningful. We generally believe that the second consultation will improve the ability of the GLEIS to produce and maintain high quality fund relationship data. We are particularly pleased that the generic category of “Other Fund Family” has been eliminated.

We recognize that use of the LEI improves the overall operational efficiencies of securities and derivatives processing, and that LEI offers some specific tangible operational benefits, such as reducing the amount of reconciliation, collapsing multiple static data points to one LEI number, providing interoperability between systems and parties, improving communication transparency and certainty, increasing opportunity to automate and utilize new technologies, and others.

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