On the 1st, March 2022 the LEI ROC (Regulatory Oversight Committee) issued new CDF (Common Data Files) Formats. LEI Worldwide have implemented the changes in its RAMP LEI management platform.
RAMP is a proprietary software tool used by Financial Institutions such as Banks, Asset Managers, Fund Administration firms who manage large portfolios of LEIs. RAMP makes it faster and easier to obtain LEIs and maintain oversight of an LEI portfolio.
LEI Fund Structure Reporting
One of the significant changes to LEI data reporting is that complex Fund structures will now be able report their structure in a more transparent manner.
Funds are required to have an LEI under a litany of global regulations such as the European Union Directive on Alternative Investment Fund Managers (AIFM) and United States regulations such as the US Dodd-Frank Act Title IV.
In the Policy issued by the LEI ROC titled “Policy on Fund Relationships and Guidelines for the registration of Investment Funds in the Global LEI System” the RIC state that a significant proportion of entities that have an LEI are investment funds.
The report describes a “limited update to the way relationships affecting investment funds are recorded in the Global LEI System (GLEIS), with the objectives of making sure that the implementation of relationship data is consistent throughout the GLEIS and providing a means to facilitate a standardized collection of fund relationship information at the global level.”
The updates allow for more detailed relationship data between entities under the entity types of ‘Fund Management Entity’, ‘Umbrella Structures’ and a ‘Master Feeder’ fund.
The new features for adding Fund structures are not and have not yet been implemented by all LOUs or LEI issuers. This means that at the time of LEI renewal Funds may need to consider moving their LEIs over to a provider that caters to this new policy. Please complete an LEI transfer request here to move your existing LEI over to RAMP which will facilitate the new requirements.
Other changes made in the CDF file formats, not related to Funds, is Legal Entity Events have been added, Government entities can report their structures and also entity creation date is a new, and highly important field for all entities applying for an LEI.
Most of the new data will be added to existing LEI at the point of annual LEI renewal, thus the GLEIF have appointed a period of one year to update the system with the new fields and requirements.
The views expressed in this blog belong to LEI Worldwide.