Imported Disclosures

Overview

Prior to implementing FundApps, most clients have a number of disclosures that have been made in the past. FundApps allows you to upload these disclosures in order to reflect this and other information in the system. Disclosures that have been uploaded into FundApps this way 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, without a prior record of holdings or disclosures, FundApps reads all positions being effectively zero the day before. This will trigger a number of initial disclosures, as FundApps will believe that 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. Normally, Imported Disclosures are uploaded just before the go-live phase.

How are Imported Disclosures used?

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 that have this requirement. If a LastDisclosureValue is not available, the property defaults to zero.

In order to make sure these rules run correctly, it is necessary to provide information into FundApps regarding previously filed positions. Once the Imported Disclosures have been uploaded, they have the same effect on subsequent disclosures as disclosures generated from uploading a positions file and filed by a user. Imported Disclosures will appear in the Result Details table to visually represent previous disclosure values.

See here for a list of rules that use LastDisclosureValue. Kindly note: historical filings can only be imported for rules that are active and approved.

How are Imported Disclosures uploaded into the system?

Please follow the instructions on the Readme document to prepare an Imported Disclosure file, shown here. Unlike other import files, we do not allow end-users to upload this information directly into the system. Only our Support team can perform the actual import, so if you have a need for Imported Disclosures, please reach out to FundApps Support and we will guide you through the process.

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