Our Issuer Limit Rules cover the major shareholding limits for jurisdictions where issuers may impose bespoke disclosure thresholds in their articles of association. These issuer-imposed thresholds may be lower or narrower than the thresholds required by the regulator.

Because there is limited guidance on how to calculate a shareholder’s percentage ownership for these thresholds, we provide eight variants of the issuer limit rules to accommodate different considerations: aggregation level (i.e., which entities and portfolios to include; this will vary by client) and aggregation structure (i.e., management or voting power; this may vary by issuer or jurisdiction).

Only four of these Issuer Limits rules should be activated in your environment at a time.

The subset of rules that you select depends on what level of aggregation you require:

AllEntities: This means that the rules will aggregate all portfolios up to a specific sub-entity and trigger a disclosure based on all the assets of the sub-entity child portfolios. Further, should a Top-Level Company be the ultimate parent, the rule will also trigger a disclosure based on the aggregate holdings across all portfolios.

AllEntitiesAndPortfolio: This means that the rules will trigger disclosures on both sub-entities and a Top-Level Company. In contrast to the "All Entities" level, a disclosure on each individual portfolio is possible here as well. So, this is a combination of "Portfolio" and "All Entities."

Once you have determined which aggregation level to use, you will know which rules to keep and which to deactivate.

In the table below, a client who chooses to use the AllEntities level will deactivate the rules in the right-hand column.

You can now control this by Global setting so that you can have all Issuer Limits Rules activated but only receive Results for one set. By default, the Global Settings are on, and so will give you results for all active Issuer Limits Rules.

You can stop receiving results for the AllEntities rules by disabling RunIssuerLimitsAllEntities.

You can stop receiving results for the AllEntitiesAndPortfolio rules by disabling RunIssuerLimitsAllEntitiesAndPortfolio.

We recommend that you disable one of the Global Settings and leave the other enabled. This should simplify future Rule approvals. If you choose not to configure the Global Settings at this time, you can continue to receive results for only one set of Rules by deactivating the rules you do not wish to use.

For more guidance regarding deactivating rules, please review the Deactivating and Reactivating Rule Versions article.

“Voting Aggregation” and “Legal Aggregation” refer to which assets will be captured by the rule, those for which the parent entity has voting power or those for which the parent entity has legal or management power. For information about the different aggregation structures, see this Aggregation Framework article.

In GCD, the “Aggregation” field determines which aggregation structure applies. An issuer with “Voting” in this field will show results for the “Voting Aggregation” rules, not the “Legal Aggregation” rules.

Most issuers in GCD have “Voting” as the aggregation structure. This is because the vast majority of issuers with limits are incorporated in France or Belgium.

Guidance in those jurisdictions clearly states that issuer limit thresholds should be calculated according to the requirements set out in the relevant statutory rules (in both cases, where one has power over voting rights).

Without specific regulatory guidance, any other issuer-imposed thresholds may apply to where either management or voting power is held.

If you believe an issuer's aggregation structure in GCD is incorrect, you can submit a request to edit the record via the Limits tab in GCD. Our regulatory team will review this request.

Our lists of issuers with limits and the lists defining how the rules operate are maintained in the Global Company Database (GCD) > Companies with Limits. For information on the source (website) for each issuer limit, go to GCD > Companies with Limits > Source.

FundApps monitors the constituents of the CAC All Tradable index to evaluate whether their governing documents contain additional thresholds. We also monitor the list provided by the Belgian regulator.

Once a limit is included in GCD, it is re-evaluated annually to check for changes. Clients may also suggest changes or additions themselves; see this article for more information.

Issuer limits in GCD are community-powered, and we encourage our clients to notify us in the manner described above if they are aware of any changes to an issuer's information.

This article explains how to submit requests to update the issuer limits.