Overview
Under Section 16(A) of the Exchange Act, disclosure obligations arise in two situations:
You cross the 10% beneficial ownership threshold in a Section 12 class, which is already handled automatically by the rules engine.
You or your firm holds a director or officer relationship with a Section 16 issuer; this requires using the HasInsiderStatus property.
The director and officer disclosure obligation is set out in the aosphere memorandum at §A12.5(a)(b).
This article explains how to set up and manage the HasInsiderStatus property to trigger automated Form 3 and Form 4 disclosure alerts independently of your ownership level.
How HasInsiderStatus Triggers Alerts
When HasInsiderStatus="true" is set on an instrument, the following scenarios will dictate which disclosure alerts are generated.
Scenario | Alert Triggered | Filing Deadline |
Director/officer status is newly active (first run with | Form 3 – Initial disclosure | Within ten calendar days |
Director/officer status is active, and there is position activity | Form 4 – Amended disclosure | Within two business days |
Director/officer status ends (HasInsiderStatus switches to "false"), and there is activity | Form 4 Final – Final disclosure | Within two business days |
Setting Up the Property
HasInsiderStatus is an issuer-level property applicable to Equity, Unit, or PreferredEquity securities. You can configure this property using one of two methods:
Option 1: Provide via a Data Override
Navigate to Admin and settings > Setup > Data Overrides.
Set HasInsiderStatus to "true" by linking to the relevant IssuerId for an Equity/Unit/PreferredEquity instrument(s).
Option 2: Provide Directly in the Positions File
Add the HasInsiderStatus field to your daily positions file.
Set the value to true for the relevant issuer.
Note: The system will generate a Form 3 alert after the first processing run where HasInsiderStatus="true" is detected. Any subsequent position activity triggers a Form 4 alert.
Removing Insider Status
When the director or officer relationship ends, remove the override on HasInsiderStatus for this issuer or change the input to "false."