Overview
This troubleshooting guide explains how rule versioning, approval dates, and effective regulatory dates interact when you re-run historical files in the system. It also details specific scenarios to help you evaluate why disclosure results might change retroactively or remain unchanged.
What This Means
When re-running a file, the rules engine automatically applies the newest rule version that is both valid and approved on the specified NAV Date, even if approval occurred after that NAV Date.
Two key fields determine which rule version evaluates your positions file:
Valid From: The date from which a rule applies to positions, representing when the underlying regulation or legislation came into force. Clarifications or interpretations retain the original Valid From date, whereas actual regulatory updates receive a new date.
Approved On: The date a user approves the rule update within the system. Approving a rule with a historical Valid From date applies retroactively to any files that are rerun with a NAV Date after that Valid From date.
Rule Scenarios and Examples
With the above in mind, please note that the system will always run the latest version of a rule that is valid and approved by you on a given NAV Date, even if the NAV Date predates your approval.
In order to demonstrate this, we have created five illustrative scenarios:
Scenario 1A - NAV Date after new rule version with unchanged reg.
Scenario 1B - NAV Date after new rule version with the new reg.
Scenario 2A - NAV Date before new rule version with unchanged reg.
Scenario 2B - NAV Date before new rule version with the new reg.
Scenario 3 - Nav Date after new, but unapproved rule version.
Scenario 1A: NAV Date After New Rule Version with Unchanged Regulation
Condition: An old rule version is in place at (1). At (2), a new version of the rule is released. The new rule version is approved by the user at (3). The underlying regulation hasn’t changed, so the new rule version’s Valid From date will be the same as the previous versions, retroactively overriding the older version between (1) and (2). Today (5), we wish to re-run a file from a previous NAV Date (4).
Outcome: The file is run on the new rule version.
Scenario 1B: NAV Date After New Rule Version with New Regulation
Condition: An old rule version is in place at point (1), and at point (2), a new rule version is released to reflect changes in the underlying regulation. The Valid From date of the new version is at (2).
The new rule version is approved by the user at (3), so any rerun of a file with NAV Date after (2) will now run on the new rule version. Today (5), we wish to re-run a file from a previous NAV Date (4).
Outcome: The file is run on the new rule version.
Scenario 2A: NAV Date Before New Rule Version with Unchanged Regulation
Condition: An old rule version is in place at (1). At (3), a new version of the rule is released. The underlying regulation hasn’t changed, so the new rule version’s Valid From date will be the same as the previous versions, retroactively overriding the older version between (1) and (3). The new version is approved by the user at (4). Today (5), we wish to re-run a file from a previous NAV Date (2).
Outcome: There is a risk of new alerts being generated because the newly approved rule version reflects additional clarification or interpretation of an unchanged underlying regulation; the Valid From date for the new rule version is (1). This means that when the file is rerun on the NAV Date associated with point (2), the new rule version will retroactively apply, even though this wasn’t approved until point (4).
This potentially means new breach/disclosure alerts will emerge that didn’t trigger under the old rule version.
Example
An existing shareholding disclosure regulation has been in place since 1 Jan 2016.
17 July: A new rule version is available due to aosphere releasing an update to their relevant memorandum. The update from aosphere was based on a clarification of the regulator's interpretation; i.e., the underlying regulation didn’t change.
20 July: The updated rule version was approved by a user.
24 July: The user re-ran a positions file from NAV Date 17 June to review some positions unrelated to the new rule version. However, the user noticed that the disclosures triggered today differed from those initially triggered on 17 June.
Since the rule version approved on 20 July reflects additional clarification of an unchanged underlying regulation, it retroactively overrides the previous version and is valid from 1 Jan 2016.
Re-running a positions file with a NAV Date after 1 Jan 2016 may trigger new disclosures.
Scenario 2B: NAV Date Before New Rule Version with New Regulation
Condition: An old rule version is in place at (1). At (3), a new rule version is released to reflect changes in the underlying regulation. The Valid From date of the new version is at (3). The new version is which is approved by the user at (4). Today (5), we wish to re-run a file from a previous NAV date (2).
Outcome: Since the new rule version was neither valid nor approved at (2), the NAV Date of the file being rerun, the old rule version will run, as it was the most recent valid and approved rule at the time of the NAV Date.
Scenario 3: NAV Date After New and Unapproved Rule Version
Condition: An old rule version is in place at (1). At (2), a new version of the rule is released. The underlying regulation hasn’t changed, so the new rule version’s Valid From date will be the same as the previous versions, retroactively overriding the older version between (1) and (2).
However, the new version hasn’t been approved yet, so when we today (4) rerun the file from NAV Date (3), the newest version of the rules will not apply.
Outcome: Risk of missing alerts because the new rule version wasn’t approved prior to (4). A file rerun at the NAV Date (3) will run on the old version of the rules, potentially omitting disclosure or breach alerts.
If at a later stage, the user approves the new rule version and subsequently reruns the file at NAV Date (3), the new rule version will apply (similar to Scenario 1A).
Example
An existing shareholding disclosure regulation has been in place since 1 Jan 2016.
24 July: A new rule version, based on an aosphere update to its relevant memorandum, is released. The update by aosphere is based on the regulator's interpretation, i.e., the underlying regulation didn’t change.
The rule has not yet been approved by the user.
26 July: The user re-runs yesterday’s file, i.e. NAV Date 25 July.
Since the new rule version is not approved, rerunning the file with NAV Date 25 July will use the old rule version, potentially omitting disclosure or breach alerts.