In a joint response to the Legal Entity Identifier Regulatory
Oversight Committee ("LEI ROC"), SIFMA, the Managed Funds
Association and ISDA (collectively, the "associations")
questioned the need for a Global LEI System
designed to "collect fund relationships that do not roll up to
the same balance sheet or financial statement." Accordingly,
the associations commended the LEI ROC decision to make the
disclosure of fund relationship structures optional. The
associations also (i) requested confirmation that, for
"umbrella" fund structures, the expectation is that the
sub-fund would be reporting, and (ii) commended the LEI ROC for
clarifying that the "Fund Management Entity" is not
necessarily the investment manager or person that performs
investment management tasks.
