Most clients have made several disclosures before implementing FundApps. FundApps allows you to upload these disclosures to reflect this and other information in the system. Thus, Disclosures uploaded into FundApps are known as Imported Disclosures.

Following the very first positions file upload, FundApps will act as if all positions are freshly purchased. This is because FundApps reads all positions as effectively zero the day before, without a prior record of holdings or disclosures. This will trigger several initial disclosures, as FundApps will believe the relevant thresholds have just been crossed. Imported Disclosures can prevent this from happening; the records of previous disclosures will act as anchor points for future subsequent disclosures. Usually, Imported Disclosures are uploaded just before the go-live phase.

They can also be used to anchor individual instruments following events like the detachment of a SPAC Unit. In such cases, imported disclosures can anchor the instruments with the new ISIN to maintain continuity.

This functionality is key for jurisdictions where subsequent disclosure requirements are based on the previous percentage that was filed. FundApps incorporates this requirement through the LastDisclosureValue property. As the name suggests, the property looks to the last disclosure value for rules requiring this. If a LastDisclosureValue is not available, the property defaults to zero.

To ensure these rules run correctly, information regarding previously filed positions must be provided to FundApps. Once the imported disclosures have been uploaded, they have the same effect on subsequent disclosures as disclosures generated from uploading a position file and filed by a user. Imported disclosures will appear in the Result Details table to visually represent previous disclosure values.

Here is a list of rules that use LastDisclosureValue. Historical filings can only be imported for active and approved rules.

Instructions in this Readme document can be used to prepare an imported disclosure file; an example is shown here. Only administrator-level users can upload this information directly to the system. Please contact our Support team if you are looking to import disclosures. We're available to help you through the process.

The following fields will be necessary when building the imported disclosure file.

RuleID: The Rule ID for the rule you’re setting up the imported disclosure. It's found at the top of any rule details page.

AggregationName: The aggregation structure on which the rule in question runs. It can be found on the rule details page under the Aggregation section.

PortfolioOrEntityID: This is the Portfolio ID utilised on the Portfolios & Entities page.

GroupKey: Every rule groups assets by the properties specified under the GroupBy clause on the rule details page. The 13G-QII rule uses both RefIssuerId and RefISINUS. In this situation, the format would be "RefIssuerId#RefISINUS."

These inputs can be found by filtering through the asset properties and ensuring the values match.

IssuerName: For identification purposes only.

ResultType: The input should be “Disclosure” for all line items.

Value: The numerical value at which the last disclosure was previously filed.

Date: YYYY-MM-DD format. This should reference the actual trade date when the disclosure value was calculated.

Q: Where can I upload this?

A: The Imported Disclosures page is under the Results dropdown. Clicking on it will take you to a page where you can review and import all imported disclosures within your environment.

Q: I’ve made a mistake with the uploaded data. What can I do?

A: If the uploaded data contains an error and a change must be made, delete the erroneous imported disclosure before uploading the corrected file.