Overview
You may have noticed both the "IsAllowedRuleExemptionClient" and "ExemptFromRuleIDs" properties in some rule versions and wondered what this does or if this section of code excludes anything important from your results.
The short of it is that this will have no effect on rule results unless you are part of a firm that has specific situations which amount to exemptions for certain positions, and your firm has worked with FundApps to turn this functionality on. This rule code does not have an effect unless FundApps has configured it to be on via the property IsAllowedRuleExemptionClient.
Does this mean that FundApps has new coding for an exemption outlined in an aosphere memo (such as market maker exemptions)?
No. The use of the ExemptFromRuleIDs functionality relates to very specific cases only. If you are interested in regulatory exemption frameworks, we would be happy to discuss that with you separately, but normally, we ask that the jurisdiction for such cases be first found in the aosphere memos.
What This Rule Feature Is For
When a client has a specific interpretation about excluding certain positions from a regime/rule which cannot be automated by usual means (and may be confidential or require judgment).
When the application of such exemptions can be flagged by the client on an asset-by-asset basis. The client would be responsible for tagging all assets (via an asset-level or position-level property) that should be excluded.
Clients who have discussed the situation-specific exemption with FundApps in depth to ensure that it meets the criteria specified.
What This Feature Is NOT For
Regulatory exemption frameworks are described to some degree in the aosphere memo (e.g. market maker exemptions).
Exemptions which are not specific to unique types of holdings.
Exemptions for which the exclusion could apply to any type of holder based on criteria defined in regulation.
Important Note
FundApps seeks to maintain a single rule set for the industry; our general approach to coding regulatory exemptions is not to simply use the functionality described in this article (which is for very specific use cases). If any of our clients are interested in a regulatory exemption, we ask that you contact us to discuss the precise nature of the exemption and appeal to Aosphere's description of the exemption framework in the memo. Requests for additional functionality in rules to handle exemptions are handled similarly to other rule enhancement requests. We would want to understand the importance of it for your firm, the nature and scope of the exemption, and assess it in light of other rule enhancement requests from our client community.