Overview
Most clients have made several disclosures before implementing the Shareholding Disclosure service. Uploading these past filings, known as Imported Disclosures, serves as a historical anchor for system calculations and future filings.
Following the first position file upload, the system treats all holdings as newly acquired because no prior record exists. This initial upload can trigger unnecessary disclosure alerts when thresholds appear to be crossed for the first time. Uploading imported disclosures prior to go-live establishes historical context, preventing false alerts and ensuring smooth continuity.
They can also be used to anchor individual instruments after events like the detachment of a SPAC Unit. In such cases, imported disclosures can anchor the instruments with the new ISIN to maintain continuity.
How Imported Disclosures Function
Imported disclosures anchor calculations in jurisdictions where disclosure obligations depend on previously filed percentages. The platform incorporates this requirement using the LastDisclosureValue property, which defaults to zero if no prior filing exists.
Once the imported disclosures have been uploaded, they have the same effect on subsequent disclosures as disclosures generated from uploading a position file and filed by a user. Imported disclosures will appear in the Result Details table to visually represent previous disclosure values.
Here is a list of rules that use LastDisclosureValue. Historical filings can only be imported for active and approved rules.
To include your last regulatory filing date, simply add it to the FiledDate column in your import file. This information will then be used to populate the previous filing date when generating disclosure forms. This is especially critical for rules within the scope of Filing Manager (see the list available here), as regulators frequently require and verify these dates.
Required Fields for the Import File
The following fields are required when building the imported disclosure file.
RuleID: The Rule ID for the rule you’re setting up the imported disclosure. It's found at the top of any rule details page.
AggregationName: The Aggregation structure on which the rule in question runs. It can be found on the rule details page under the Aggregation section.
PortfolioOrEntityID: This is the Portfolio ID utilised on the Portfolios & Entities page.
GroupKey: Every rule groups assets by the properties specified under the GroupBy clause on the rule details page. The 13G-QII rule uses both RefIssuerId and RefISINUS.
In this situation, the user would replace the ISIN and IssuerId columns in the example file linked below with GroupKey as the header. The input would have the following format: "RefIssuerId#RefISINUS."
These inputs can be found by filtering through the asset properties and ensuring the values match.
IssuerName: For identification purposes only.
ResultType: The input should be “Disclosure” for all line items.
Value: The numerical value at which the last disclosure was previously filed.
Date: YYYY-MM-DD format. This should reference the actual trade date when the disclosure value was calculated.
FiledDate: YYYY-MM-DD format. This must be the date this disclosure was filed with the regulator, NOT the position date.
Uploading Imported Disclosures
Instructions for preparing an imported disclosure file are also in our technical documentation and can be found here.
Only administrator-level users can upload imported disclosure files directly.
To review or upload files, navigate to Monitoring > Shareholding Disclosure, select the Results dropdown and click Imported Disclosures.
For help during file preparation or uploading, contact the Support team.
Frequently Asked Questions
Q: Where can I upload my imported disclosures?
A: The Imported Disclosures page is under the Results dropdown when looking at the Shareholding Disclosure screen. Clicking it takes you to a page where you can review and upload all disclosures that have been imported into your environment.
Q: I’ve made a mistake with the uploaded data. What can I do?
A: If the uploaded data contains an error and a change must be made, delete the erroneous imported disclosure before uploading the corrected file.