Overview
One of the core pillars of our service is aosphere’s legal interpretations, and their memos must support all changes to our Rules.
Therefore, we do not support client-specific customisation of rules or aggregation trees that deviate from aosphere.
The one potential exception to this would be if there are clear statements from a regulator on a given point, but these would need to be reviewed on a case-by-case basis by our Regulatory team. After such a review, the decision to extend rule and aggregation functionality is at the discretion of FundApps. Any evidence that can aid proposed changes to our rules and/or interpretation should follow the structure as documented in this Help Centre article.
Discussing with aosphere
We are interested in regulatory analysis clients may have received from counsel regarding topics covered in aosphere memos, as this can inform our ongoing dialogue with aosphere regarding points of interest to our wider client base and broader discussions regarding memoranda content. We prefer to liaise with aosphere on our client’s behalf in such cases.
However, if a topic is unlikely to be of interest to our wider client base or if it regards a topic outside of the scope of aosphere’s coverage, we encourage clients to continue to establish their own relationships with aosphere and advocate for enhancements to be made across aosphere’s Rulefinder product. Many clients who have built their own relationship with aosphere have experienced a personalised response based on their specific topic, which may not have been raised during broader discussions that FundApps have with aosphere.
Future Plans
With regards to future flexibility where interpretations differ, we do not plan to give clients discretion in implementing bespoke aggregation structures they believe are required for two reasons:
From a practical perspective, we would be unable to support queries across our client base if different rules and aggregation structures were applied. We would not be able to determine whether an unexpected result was due to something on our end or to a client-specific customisation.
From a philosophical point of view, we believe that there is one set of regulatory requirements, and there is no basis for clients in the same jurisdiction to have different implementations of a given requirement. In other words, one set of regulatory requirements applies in one way.
As with all aspects of our service, we will continue to evaluate potential enhancements based on market demand and impact, with a view to sustainably developing a product that adds value to our clients. We appreciate any feedback you have as we continue to improve our service.