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.

The associations also provided detailed responses to an LEI ROC questionnaire as part of the second consultation document on fund relationships in the Global LEI System.

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