Some disclosure regimes apply differently to different types of investors. For example, the major shareholding regime in the United Kingdom (UK) applies differently depending on whether the investor is a UK investment manager. The thresholds for a major shareholder are lower for non-UK investment managers.

The rules engine distinguishes between the various applications for specific disclosure regimes using the portfolio property CompanyType. This property determines which set of rules will run against the uploaded positions. You can set more than one CompanyType for a given entity.

The determination of which rules to run happens in the precondition of a rule, where the value of the CompanyType property is used as the input.
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The system does not fully support an entity aggregation hierarchy where entities or portfolios have mixed company types. For example, if you have both UK Investment Manager (UKIM) and non-UKIM entities within your structure, we recommend avoiding the tag entirely to stay conservative. To discuss these scenarios further, please contact your CSM or Support.

The jurisdictions that distinguish between different company types are Canada, the UK, the United States (US), Italy, South Korea, and South Africa. Any rule using a specific CompanyType designation displays this under its Precondition parameters.

Review the valid CompanyType values and their operational impacts below.

Consider this value for every entity and portfolio. It confirms whether the entity or portfolio is an eligible institutional investor (EII) per Canada's rules. EIIs include:

If the entity or portfolio is an EII, include AMRS as a value in its CompanyType. Setting this value ensures the entity or portfolio uses the Alternative Monthly Reporting System (AMRS) procedure rather than the Early Warning Report. Before selecting this value, read and understand section A.3.1.2 ("An EII for these purposes means...") of the Canadian aosphere memo.

You must evaluate whether:

The rules engine evaluates each entity's and portfolio's obligation regarding its own status, aligning with memo section A.7.2.
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Determining EII status and setting AMRS is an exemption framework rather than a requirement. If you are uncertain, treat entities or portfolios as non-EIIs and omit AMRS.

Consider this value for every entity. It stands for a UK investment manager, European Economic Area (EEA) investment manager, or non-EEA investment manager equivalent. Review section A.6.2 of the UK aosphere memo for the exact definition before selecting this value.
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This setting allows all EEA and non-EEA investment managers to disclose at the European Union (EU) minimum thresholds of 5% and 10%. This avoids the lower 3% threshold with 1% incremental thresholds that apply to holdings in UK issuers. The manager must be able to lawfully manage those investments in a non-EEA state, and managing their investments in the UK must require Part 4A permission. The UK regulatory note defines this requirement.

For MajorUS rules related to Section 13, the rules engine runs the 13D regime (MajorUS - 13D) by default. It runs 13G only if you confirm that all entities in the aggregation tree meet the requirements of either a Qualified Institutional Investor (QII) or a Passive Investor.

The system supports using only one filing type for the whole company. Set all entities to the same value without mixing them.

Consider this value for every entity and portfolio. It ensures the system invokes the 13G Passive Investor version of the Section 13 rules. If your firm's entities are US QIIs, select US-QII instead.
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If an entity is a passive investor (defined in Section 240.13d-1(c) of the Securities Exchange Act of 1934), include this value. See US aosphere memo sections 1.7(b)(iii) and 7.2(c) for details.

Apply this CompanyType value if an entity or portfolio is a QII as defined by Section 240.13d-1(b)(1)(ii)(A)-(K) of the Securities Exchange Act of 1934 (excluding 240.13d-1(b)(1)(ii)(G)).

Apply this value to any top entity that is a parent of a QII. As defined in 240.13d-1(b)(1)(ii)(G), if a QII entity or portfolio is owned, managed, or held via voting rights by a parent or control person entity, the parent can also be a QII. This applies provided the parent, its subsidiaries, or its non-QII affiliates do not directly or indirectly hold more than 1% of the subject class securities.
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When you set US-QII-Parent for an entity, the rules engine applies a monitoring rule to determine whether the parent breaches this condition for a given share class. Only apply US-QII-Parent to the top entity, as the monitoring rule runs strictly at this level. See the US aosphere memo and Section 240.13d-1(b) for details.
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For the monitoring rule to work effectively, apply US-QII to the portfolios of a US-QII entity. If you do not provide US-QII, US-QII-Parent, or USPassiveInvestor, the 13D rule will apply.

If you state no US Section 13 CompanyType values, the system will run the US 13D regime by default. If specific issuers qualify for 13G:

Consider this value for every portfolio. Setting this CompanyType excludes the portfolio's assets from all 13D and 13G rules. Only set this value if one of the exemptions in 17 CFR § 240.13d-3(d) applies to all assets in that portfolio:

Consider this value for every entity. This confirms the entity and its controlling entities are equivalent to an Italian or European asset manager or financial intermediary. This applies to a non-EU asset manager if it would face similar regulations when set up in Europe. Read and understand section A.6.16 of the Italy aosphere memo before declaring this value.
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For direct parent entities of a portfolio, assess whether they meet the memo criteria. For entities that control or partially own the direct parent, assess whether they can rely on this exemption. The memo states that you must assess controlling entities on a case-by-case basis if they do not meet disaggregation requirements.
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Only use this value if all entities meet the requirements. Set it consistently across all entities in the aggregation tree without mixing entities with and without ITFM. If all entities do not qualify, do not apply this optional exemption value to any entity.

Consider this value for every portfolio. This confirms the portfolio is:

Including NotZA is recommended unless specific portfolios or legal entities are organised under South African laws and meet the criteria above.
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Under the Financial Markets Act (FMA) regime, a non-South African financial institution might still need to disclose under specific circumstances. However, teh rules engine does not evaluate those specific circumstances if you set NotZA as a CompanyType.

Consider this value for every entity and portfolio. This ensures the Passive Investor version of the South Korean 5% rule is invoked. If a top entity or portfolio is a passive investor (whose equity ownership purpose is not company management), include this value. See section A.1.4 of the South Korea aosphere memo or the Financial Supervisory Service guide for details.

Consider this value for every entity and portfolio. This excludes entities and portfolios not deemed beneficial owners under Section 16(a) in the US from the following rules:

For more information on beneficial ownership definitions under Section 16(a), see section B.1.6 of the aosphere memo or the guidance note.

Consider this value for every entity and portfolio. This confirms whether the entity acquires securities in the ordinary course of business and is a broker, bank, or specified institutional investor under SRC Rule 18.1.3 (Section 1.4 of the Philippines aosphere memo). Setting this value qualifies the entity for the less onerous Short SEC Form 18-AS disclosure instead of the Long SEC Form 18-A.

Consider this value for every entity, including the top entity. This applies to co-holders under the Japan regime who act as concert parties. Concert parties in this arrangement have agreed to transact or vote jointly, typically when the parent holds only a minority of voting rights in the subsidiary. Setting this value excludes concert parties from the mandatory 0.1% exemption.
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Most clients are co-holders using the controlled undertaking structure rather than the concert parties structure. Read more about the Japan exemption rules here.

Consider this value for every entity and portfolio within your environment. Apply this value when all assets of a given entity must be aggregated for ShortHK rules.
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When applied to entities, the rules engine evaluates those entities under the following rules that aggregate at the entity level:

When applied to portfolios, the system excludes those portfolios from the following rules that aggregate at the portfolio or umbrella level:

Consider this value for every umbrella and portfolio within your environment. Apply this value when all assets in a multi-managed fund (umbrella) must aggregate at the umbrella level instead of the sub-fund (portfolio) level for ShortHK rules.
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When applied to umbrellas and portfolios, the system evaluates assets under the following umbrella-level aggregation rules:

It also excludes them from the following portfolio-level rules:

Per section E.2(c)(c) of the aosphere memo, calculate the multi-managed fund-level position by aggregating net short portfolio positions and ignoring net long positions. Refer to points 2.6-2.10 of the guidance notes for more information.

Important Note: If you do not define a ShortHK CompanyType, standard rules apply and aggregate at the portfolio level:

This default behaviour applies to most standard single-managed funds with an entity above them.