Overriding FIRDS and FCA FIRDS Data for SSR Rules
For the SSR EU and SSR UK rules, FundApps uses the FIRDS and FCA FIRDS databases to determine whether an instrument falls in scope. It does this by looking up the client-provided ISIN within the relevant database. There is more information about this process here.
Per that article, we are aware that, on occasion, clients may have a different interpretation of the data provided within the FIRDS database or may believe an instrument is out of scope for other reasons. If the instrument should be added to the Exempted Shares List, we encourage clients to contact the relevant RCA to make this determination and push them to adjust their data as required.
However, if there are issues with the FIRDS data, clients do have the option to manually override the data coming from FIRDS. There are several relevant properties used within the rules’ code.
For the EU SSR rules (excl. Netherlands):
For the NL SSR rules:
Using the ISIN as the conditional properties, if clients set both these properties to NONE via the data overrides page, the instrument will fall out of scope of the given SSR EU regime.
For the SSR GB rules:
Similarly, using the ISIN as the conditional properties, if clients set both these properties to FALSE via the data overrides page, the instrument will fall out of scope of the UK rules (note, here, this is FALSE rather than NONE)
There are risks with this approach, namely that clients will need to monitor these to determine that they remain applicable over time.
Also, please note that the CountryOfRCARegulatedMarkets property is also used by the French Takeover rules. Therefore, if you were to set this to NONE, the instrument would be scoped out of the French Takeover rules so we do not recommend using this for the French rules.