Applying for an LEI number for a fund

An investment fund, pension fund or sub-fund may need an LEI number where the fund carries out financial transactions, trades derivatives, issues a financial instrument, or must be separately identified for reporting purposes.

A fund’s LEI number is not the same as the fund manager’s LEI number. Where a transaction or report concerns the fund, it’s the fund itself that must be identified. The fund manager’s LEI number is used separately, where it’s the fund manager or the person responsible for reporting who must be identified.

Applying for an LEI number for a fund is similar to a standard company application, but the verification of details can be more thorough. This is because a fund may be a contractual fund, an investment company, a pension fund, a sub-fund of an umbrella fund, or another legal structure.

When does a fund need an LEI number?

A fund may need an LEI number where it participates in the financial market in its own name or must be separately identified for reporting. An LEI number may be needed, for example, where the fund:

• buys or sells securities;
• trades derivatives;
• is a counterparty to a derivative contract;
• issues financial instruments;
• is part of an umbrella fund or a master-feeder structure;
• needs to be identifiable to a bank, broker, depositary, trading venue or supervisory authority.

Under EMIR reporting, the counterparty to a derivative contract is usually the fund itself. For an umbrella fund, the counterparty may be a sub-fund. The fund manager may submit the report on the fund’s behalf, but the fund’s own identifier is used to identify the fund.

Is the fund manager’s LEI number enough?

Where a transaction or report concerns the fund, the fund manager’s LEI number is usually not enough.

The fund manager’s LEI number identifies the fund manager. The fund’s LEI number identifies the specific fund. Where the same fund manager runs several funds, the fund manager’s LEI number doesn’t replace each fund’s own separate LEI number.

This matters in particular where the funds operate under different investment strategies, have separate investors, or their assets and liabilities are segregated from one another.

How many LEI numbers does a fund structure need?

The need for an LEI number depends on the fund’s structure and which entity must be identified in the transaction or report.

Where a fund manager runs several separate funds, each fund needs its own LEI number if each fund must be separately identified in the financial market.

For an umbrella fund, an LEI number may be needed for both the umbrella fund and the sub-fund. Where a transaction or financial instrument relates to a specific sub-fund, the sub-fund’s LEI number must be used.

In a master-feeder structure, both the master fund and the feeder funds may need their own LEI numbers, where they must be separately identified in transactions, reporting, or fund relationships.

What information is requested when applying for a fund?

A fund application must provide the fund’s core details and, where relevant, its fund relationships. You will usually need the following information:

• the fund’s official name;
• the fund’s registration number or other official identifier, if it has one;
• the fund type, for example UCITS, AIF, pension fund or sub-fund;
• the fund’s country of registration and address;
• the fund manager’s name and registration number;
• whether the fund is a sub-fund of an umbrella fund;
• details of any master-feeder relationship, where relevant;
• the contact person’s details.

Accuracy matters when it comes to the fund’s name. For a sub-fund, the name or supporting documents must also make clear the name of the umbrella fund, since sub-funds with the same or similar names can exist under different umbrella funds.

What documents might be needed?

Fund details are verified against official registers and the fund’s own documents. Verification may rely on the relevant financial regulator’s or fund registry’s public records. Where necessary, a document confirming the fund’s name, type, structure or fund manager will also be requested.

Additional documents that might be needed include, for example:

• the fund rules;
• the prospectus;
• the fund’s articles of association;
• a register extract;
• confirmation from the fund manager;
• a document showing the relationship between the umbrella fund and the sub-fund;
• a document showing the master-feeder relationship.

For an overseas fund, details are verified against that country’s register or its supervisory authority’s database. If the public register doesn’t give enough information, an official register extract, prospectus, or other document confirming the fund’s existence and structure may need to be submitted.

Applying step by step

When applying for an LEI number for a fund, it’s worth gathering the necessary information and documents before you submit the application.

1. Choose a package. Choose a 1-, 3- or 5-year package. With a longer package, we manage the annual renewals throughout the chosen period.
2. Enter the fund’s details. Enter the fund’s official name and registration number or other official identifier, if it has one, in the application form.
3. Add the fund manager’s details. Enter the fund manager’s name and registration number. If the fund is self-managed, note this in the application.
4. Describe the fund’s structure. Indicate whether it’s a standalone fund, a sub-fund of an umbrella fund, or part of a master-feeder structure.
5. Upload documents if needed. Add the fund rules, prospectus, articles of association or another document, if this is needed to verify the details.
6. Submit the application and make the payment. Once the application has been submitted, the details are reviewed. If further information is needed, LEI Universal will get in touch.

How long does it take to issue an LEI number for a fund?

The processing time for a fund application depends on how easily the fund’s details can be verified.

If the fund’s details are available in an official register and the documents submitted are sufficient, the application can be processed more quickly. Where an umbrella fund, sub-fund, master-feeder structure, or overseas documents need to be checked, issuing the number can take longer than for a standard company.

For that reason, it’s worth not leaving a fund’s LEI number application until the last minute, especially where the number is needed for a bank, a broker, or a reporting obligation.

What happens after the LEI number is issued?

Once issued, the fund’s LEI number is entered into GLEIF’s public database. From there, you can check the fund’s name, its LEI number status, and other public details.

The LEI number must be renewed once a year. If it isn’t renewed, its status becomes lapsed, which can hold up transactions or reporting.

With a multi-year package, LEI Universal manages the annual renewals throughout the chosen period. Read more: Renewing your LEI number

Frequently asked questions

Does every fund need its own LEI number?

If the fund needs to be separately identified in a financial transaction, in reporting, or as an issuer, the fund needs its own LEI number. The fund manager’s LEI number doesn’t replace the fund’s own LEI number.

Does a sub-fund need its own LEI number?

Yes, where a transaction, report or financial instrument relates to a specific sub-fund. In that case, the sub-fund itself must be identified, not just the umbrella fund or the fund manager.

Does a fund need to be a legal entity to get an LEI number?

Not always, in the usual company-law sense. A fund can also be a contractual fund or another legal structure. What matters is that the fund can be separately identified within the LEI system and that its details can be verified.

Who can apply for an LEI number for a fund?

The application is usually submitted by the fund manager or another authorized person. If the applicant doesn’t have sufficient authority to represent the fund, a letter of authorization may be needed.

Why might a fund application take longer?

A fund’s structure can be more complex than a standard company’s. It may be necessary to verify the fund rules, the prospectus, the fund manager, the relationship between an umbrella fund and a sub-fund, or a master-feeder structure.

Can you apply for an LEI number for a pension fund?

Yes, where the pension fund needs to be separately identified in a financial transaction or in reporting. For the application, the pension fund’s details are verified against official registers and, where necessary, the fund’s own documents.