Overview
This article explains how to successfully submit disclosures to the Federal Gazette using Filing Manager. It covers:
How to validate your form data before submission.
Where issuer data is sourced from and how to verify it.
How result statuses are updated when both BaFin and the Federal Gazette are enabled.
The correct submission workflow for private and public disclosures.
Following these steps will help prevent rejected filings.
Validate Form Data Before Submission
We strongly recommend users validate their form data by reviewing the Forms Properties tab in the disclosure result before submitting using Filing Manager.
Please ensure that the Reporting Person's address in FundApps matches the address registered with the Federal Gazette.
This validation is performed on the Federal Gazette side. If the addresses do not match, the filing will be rejected.
Where Issuer Data Is Sourced
Issuer data is sourced from the Global Company Database (GCD), which is accessible from the top menu bar under Data > Global Company Database.
Enter the ISIN, LEI, or Issuer name and click Search. Locate the issuer in question from the resulting list, and click on the highlighted Legal Name.
IssuerCity and IssuerCountryCode can be found under the General tab by scrolling to the Legal Address section at the bottom.
IssuerLegalForm will be found under the Registration tab > Other Details > Entity Legal Form - Name.
For German issuers, the following fields are also required:
IssuerRegisterCourt
IssuerRegisterType
IssuerRegisterNumber
These fields are located under the Germany (Used in Disclosure Forms) section of the Country Specific tab.
If any of these fields are missing or incorrect, please follow these instructions to populate the data.
How Result Statuses Are Updated
When both BaFin (private disclosure) and the Federal Gazette (public disclosure) are enabled in Filing Manager, the results should be updated based on the status of filings across both regulators.
This means that results in the Shareholding Disclosure will only be automatically marked as Filed by the Filing Manager once both BaFin and Federal Gazette filings have been filed.
Status Possibilities
Filing Manager BaFin | Filing Manager Federal Gazette | Shareholding Disclosure |
Unactioned | Unactioned | Unactioned |
Disclosing | Unactioned | Disclosing |
Disclosing | Disclosing | Disclosing |
Error | Unactioned | Disclosing |
Error | Disclosing | Disclosing |
Error | Error | Disclosing |
Error | Filed | Disclosing |
Rejected by Regulator | Unactioned | Disclosing |
Rejected by Regulator | Disclosing | Disclosing |
Rejected by Regulator | Error | Disclosing |
Rejected by Regulator | Rejected by Regulator | Disclosing |
Rejected by Regulator | Filed | Disclosing |
Filed | Unactioned | Disclosing |
Filed | Disclosing | Disclosing |
Filed | Error | Disclosing |
Filed | Rejected by Regulator | Disclosing |
Filed | Filed | Filed |
Filed | filing not required for result* | Filed |
* means for private disclosures only.
If only a BaFin filing exists for a result, that result will be updated as normal based on the status of that BaFin filing.
Sending Federal Gazette Filings
The usual workflow when submitting a position that requires both private (BaFin) and public (Federal Gazette) disclosures is to:
Submit the private (BaFin) disclosure.
Confirm the submission was accepted by the regulator.
Submit the public (Federal Gazette) disclosure.
When sending Federal Gazette filings, you will be warned if any of those filings do not have a corresponding BaFin filing with a Filed status.
A confirmation pop-up for the Federal Gazette submission will display this warning and allow you to choose between (1) submitting only the filings to the Federal Gazette which have been marked as Filed in BaFin, or (2) submitting all filings, including the ones without a Filed BaFin counterpart.
Federal Gazette FAQs
Q: Where is my issuer data being sourced from?
A: The issuer data is being sourced from our Global Company Database (GCD).
Q: How to proceed if my issuer data is wrong or missing?
A: Given that this data is sourced from GCD, you will need to request a data update following the instructions here. Once the data is updated in GCD, you will need to re-run your position file to update the missing data points in the XML file before attempting to file with Filing Manager.