The property Has13GDisclosureRequirement allows FundApps users to manually generate a 13G disclosure result for an instrument. Using an Asset Data Override to set Has13GDisclosureRequirement = True for an instrument will trigger a 13G disclosure result for every in-scope entity and portfolio that holds the instrument. Users can then mark as filed or reject as applicable.
Has13GDisclosureRequirement should be set for a single NAV date and the position file for that date should be re-run in order to manually generate a 13G disclosure result.
Users may want to manually generate a disclosure result if a 13G filing was submitted that included a reporting person that did not individually trigger a disclosure result in FundApps.
FundApps calculates initial and subsequent disclosures systematically for each individual 13G reporting person (Holding companies, Asset Manager, Fund, etc.) at the top, entity, and portfolio level. There can be a case where an entity and portfolio are required to file a 13G passive disclosure with respect to the same securities. Typically the user would report the information for all entities and portfolios with respect to the same securities on a single 13G disclosure form as a joint filing under 13d-1(k).
Example: NAV day 1
On NAV day 1 John Smith Asset Management Co., LLC will trigger a passive 13G disclosure at the entity level for having passive beneficial ownership of 6% of ABC Corp. The 13G filing will name John Smith Asset Management Co., LLC as the single reporting person.
Example: NAV day 2
On NAV day 2 John Smith Partners Global Macro Fund, LP crosses 5% beneficial ownership and triggers a passive 13G disclosure result in FundApps at the portfolio level. In this case the reporter may want to name John Smith Asset Management Co., LLC at 8.5%, and John Smith Partners Global Macro Fund, LP at 5.5% as two reporting persons on the same Form 13G because both the entity and portfolio are filing with shared beneficial ownership with respect to the same securities.
For NAV day 2 FundApps Results will trigger a disclosure result for John Smith Partners Global Macro Fund, LP but not John Smith Asset Management Co., LLC.
If a user wants to trigger a disclosure alert for John Smith Asset Management Co., LLC on day 2, the user will have to set Has13GDisclosureRequirement = True and re-run the positions file for NAV day 2. The override should be set on the ABC Corp ISIN for a single NAV date. After the position file re-runs a disclosure result will trigger for John Smith Asset Management Co., LLC, John Smith Partners Absolute Return Fund, LP, and John Smith Partners Global Marco Fund, LP. The results for John Smith Partners Global Macro Fund, LP, and John Smith Asset Management Co., LLC will be marked as filed. The result for John Smith Partners Absolute Return Fund, LP will be rejected because it did not cross 5% and was not named as a reporting person on the Form 13G for NAV day2.
Please note: Has13GDisclosureRequirement should be set to true for the ISIN of the Class of equity security reported on the 13G filing submitted. For a derivative security (ADR, Option, Convertible) the property should be set on the reportable underlying equity ISIN.