The rules engine can differentiate between portfolios and automatically net positions according to the relevant rules.

All rules are designed to net (or not net) positions according to the specific regulation they cover, rather than requiring clients to pre-net their assets in a way that affects street-facing positions.

For firms that operate pod structures or have multiple portfolio management teams operating within the same fund/portfolio, be mindful of scenarios where individual pods’ positions within that fund are offset internally rather than through external borrowing. Some adjustments may be needed here to show the street-facing position.

Further, we do not expect any pre-netting to take place where there are external transactions involved (e.g. where short positions are covered with stock borrowed from a PB), opposing positions are held in different funds (i.e. portfolios within our environment) or managed by different entities (including in sleeves of the same fund managed by different entities).

If you have any questions about a particular rule or how positions are netted, please contact our Support team or your CSM.