Overview
Clients often have multiple positions they expect to trigger results under the European Union (EU) Short Selling Regulation (SSR) rules. However, when a result is generated, one or more positions may be missing from the final calculation. This article explains why certain positions are excluded and how to troubleshoot these discrepancies.
FundApps automatically evaluates your portfolio against regulatory requirements, but specific exemptions, netting rules, and data settings can cause positions to be filtered out of the results.
What This Means
When a position is missing from a result, it means the security has been filtered out of the specific EU SSR rule calculation. While these positions remain visible in the Entity Assets table for that date, they are not included in the total net short result.
Why It Happens
There are four primary reasons why a position may be excluded from your EU SSR calculations.
1. The EU SSR ESMA Exempt Shares List
If a security has a principal trading venue located outside the EU, it may be included on the European Securities and Markets Authority (ESMA) Exempt Shares List. The FundApps engine automatically excludes any position on this list from SSR calculations
2. The Custom EU Short Selling Exempt List
Positions are excluded if they relate to instruments defined on your organisation's EU Short Selling Exempt Custom List. If no instruments are defined on this custom list, the rule applies the standard ESMA exemptions.
3. Portfolio-Level Netting
The engine automatically nets long and short positions at the portfolio level.
Net Long Outcome: If the total outcome of all positions for a specific issuer within a portfolio is long, those positions are excluded from the calculation.
Aggregation: The engine only aggregates portfolios that have a net short position up to the top entity.
4. CFI Code Exclusions
If the IsSSREquityExcludingCFI global setting is enabled, the engine will exclude assets where the Classification of Financial Instruments (CFI) code does not start with the following:
ES
EP
EC
EF
How to Resolve Discrepancies
If you believe a position should be included, follow these steps to verify your data:
Check the ESMA List: Confirm if the security is currently listed on the official ESMA Exempt Shares List.
Review Custom Exemptions: Check your EU Short Selling Exempt Custom List to see if the instrument has been manually exempted by your team.
Verify Netting with Look-Throughs: Access the Entity Assets table via the Portfolios & Entities screen.
Set the filter to Include look-throughs.
Review all underlying assets to ensure the total number of long and short positions results in a net short position.
Confirm CFI Data and Settings: If the IsSSREquityExcludingCFI global setting is set to True, verify that the asset's CFI code is accurate and starts with the relevant characters (ES, EP, EC, or EF).
Contact Support: If you have checked the lists and netting but the position is still not captured, contact FundApps Support via the In-App Messenger or by emailing [email protected] for further assistance.
FAQ
Q: I've looked at my Entity Assets table, and I can only see short positions. Why haven't these been included in the calculation?
A: It's important to remember that netting includes all the underlying assets of a position as well, so when you're looking at the Entity Assets table, you need to ensure that the Filter is set to Include look-throughs.
This will ensure that all underlying assets are also displayed so you can calculate the total number of Long and Short positions held in that Portfolio.
For more information about how netting works for the EU SSR rules, we have put together a Help Centre article titled "EU SSR Rules Netting Explained."
Q: I've checked everything and still can't see why my position hasn't been included?
A: There may be a specific reason why a position hasn't been captured that falls outside the scope of this article. If you've checked the ESMA Exempt Shares list and you've double-checked your netting, but you still think a position is not being captured when it should be, please feel free to reach out to FundApps Support via the In-App Messenger or by emailing [email protected] for further assistance.