December 1, 2017

Via Email ([email protected])

Legal Entity Identifier Regulatory Oversight Committee

Re: Consultation Document on Funds Relationships in the Global Legal Entity Identifier (“LEI”) System

Dear Sirs and Madams:

The undersigned associations (the “Associations”)1 appreciate the opportunity to provide feedback to the LEI Regulatory Oversight Committee (“ROC”) regarding the Consultation Document on Funds Relationships in the Global LEI System (the “GLEIS”).2 The Consultation proposes to “update the way relationships funds have with other entities are recorded in the GLEIS, to both capture worldwide a fund’s relationship with its management entity regardless of different legal and accounting framework[s] under which they are organized, and improve the way funds relationships are recorded.”3

We believe that the use of LEIs in financial markets has brought efficiency and greater data integrity to trade reporting and risk management. As such, the Associations are committed to helping support the evolution of the LEI to achieve these aims. While the Associations disagree with a significant portion of the proposal set forth in the Consultation, the Associations offer to assist the ROC in an evaluation of the regulatory use cases and how the ROC’s objectives can be achieved without the burden that would be imposed by the proposed approach.

The Associations recognize the importance of data; however, we have significant concerns with the proposal. The Associations believe that the LEI system should not mandate the proposed fund relationship information. We are not convinced that the benefits of the cited regulatory objectives outweigh the significant operational and cost burden this collection would impose upon funds and their managers. The burden of determining, reporting, verifying and updating fund relationship information when considered across all types of fund and fund management relationships globally is extraordinary. As discussed below, we believe the regulators already have tools that serve many of the ROC’s stated objectives. Additionally, because of the diversity of funds and fund management relationships globally, we are concerned that the data collected would not be sufficiently standardized to be relied upon, thus leading to data quality concerns and potential misinformation. For these reasons, the Associations believe that ease of obtaining an LEI and its current broad use will be undermined by adding requirements that go beyond requiring entities consolidated on financial statements to report their accounting parent information.

Instead of proceeding with the proposed fund relationship requirements, the Associations recommend further study of this topic including possible additions to the current LEI Level 1 requirements for fund entities and managers. For fund relationships, we believe starting with the collection of more specific definitions for use in the optional Level 1 fund family field would help the ROC observe whether collecting additional information would be useful (see response to Question 6 below). In addition, as discussed further in response to Question 12, we believe that providing an option for investment strategies that cannot currently obtain an LEI—for example, segregated mandates of assets managed below that of a legal entity—may be an area where further study and additional options within the LEI system would be helpful.

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1 See end of letter for descriptions of the Securities Industry and Financial Markets Association’s Asset Management Group (“SIFMA AMG” or “AMG”), the Investment Adviser Association (“IAA”), the Investment Company Institute (“ICI”), and the Managed Funds Association (“MFA”).

2 Referred to herein as the “Consultation,” available at: https://www.leiroc.org/publications/gls/roc_20170926-1.copy-1.pdf.

3 Consultation at 3.