Overview
FundApps has automated the process to disclose net short position with Finansinspektionen, the Swedish regulator, to ensure your Filing Manager is ready to be used with this jurisdiction. Please follow the instructions below.
Make sure you have saved in your Portfolios/Entities page under “Forms Properties” the LEI of the Entity reporting the position. We need this information to validate that we are passing the correct data to the regulator.
Set up your acceptable threshold for the Total Shares Outstanding variance in FM FISE Settings.
To proceed with the login process, you can access the “One Touch” app on your phone (more information about this process can be found here).
Workflow
After the user reviewed their ShortSE disclosure data, when they navigate to FM FISE screen and click “SEND”, then:
FM FISE will fetch the One Touch QR code and make it available in the FM screen so that the user can validate their login credentials.
FM FISE populates the issuer data in the portal.
Validation 1: The Swedish portal automatically populates “The issuer’s total amount of issued shares (all share classes)”. If this value doesn’t match the value provided to FundApps, we will use the acceptable variance saved in FM FISE settings to determine if we should proceed with the filing. If the value is outside the acceptable variance, we will stop the filing and alert the user. The acceptable variance is calculated as (| portalTSO - clientTSO | / clientTSO) * 100.
Validation 2: The field “Position in percent(%)” is automatically calculated on the website once the position in number of shares is completed. If this value matches the value from FundApps, we will proceed with the filing. If not, we will stop the filing and alert the user.
The disclosure has been completed, and FM FISE will display the position as “Filed”.
If the validation fails, either due to the TSO variance or due to mismatch of position in percent, the automation will stop and the position will be set to “Unactioned” in FM with the submission message explaining the reason. To proceed with the filing, the user should:
Adjust their TSO data in FundApps before trying to submit the position again.
Continue with manual filling in the Swedish portal.