Disclosure instructions for Major: Poland

**IMPORTANT**: The new Poland web forms have requirements not seen before. As a consequence, FundApps does not currently have code functionality to capture the BEFORE and AFTER data BY ENTITY in a single calculated table. The data generated here is for the AFTER results. To get the data for the BEFORE results, please use the Excel document generated for the previous day's results. Data will need to be manually copied into the appropriate web form.

If reporting at the portfolio level, please use the PortfoliosData tab. The entity-level values will not populate.

There are six choices of form templates to use on the website. While the key data is largely the same, there are differences in format and some of the required data. The different form types are explained at the portal entrance and in the user manual. It will be up to each client to determine which one they should use.

Portal home page:

User manual:
In this discussion, we will look at Form A. Enter like this:
And here is an "unexpanded" view. Note the down arrows to expand each section:
Because this is a web form, clients will have to enter the data manually. Here are the first sections:
The data for these (when running the disclosure report for an entity) are on the Main tab of the new Excel document. Here, we are disclosing at the Top Entity level. Because the data for each entity is required, disclosing at the top entity allows us to populate all the data in one disclosure.

Below is the next section. The area with the vertical highlight line is filled based on the data provided for the direct and indirect holdings. Note the two check boxes marked "A". The first one is for shares held "directly". This is where the reporting entity has portfolio(s) that are held directly by it. There are no other entities between the reporting entity and the portfolio(s). The check box below is for assets held in portfolios below the reporting entity. These are indirect holdings in terms of the reporting entity. They are held by the sub-entities. Also, note the BEFORE totals section - which has an "X" next to the header.
When the first check box is selected, a new section appears:
This is for holdings directly held by the reporting entity. Where the reporting entity has a portfolio (or more than one) directly under it in the aggregation tree. Here it is when expanded (click the down arrow in the header)
As mentioned at the start, this new data requirement is unique in that it requires disclosure by ENTITY, and also the BEFORE and AFTER data. To fill this BEFORE section out for the DIRECT holdings of the REPORTING entity, you will have to go to the previous day's disclosure and generate the disclosure document. Save that document to your computer, and have today's disclosure document and the previous day's open to have access to all the data required to fill in the portal. From the previous day's document, go to the second tab (EntitiesData) and find the row that has a blank row above it and below it. This table uses ESMA forms' "chain of control" functionality to return each branch of the reporting tree. Only entities are visible in this structure, not portfolios, so a row on its own is the reporting entity's direct holdings. Take the highlighted data from the BEFORE spreadsheet and copy/paste it into the boxes above that have just been made visible when clicking the "shares held directly" check box.
Now for the "dependent entities", the ones under the reporting entity. If the second box in the highlighted section "A" - "Shares held directly, through subsidiaries" is checked, then this appears:
Then clicking on the small down arrow in the header produces this:
Note the highlighted row above auto-sums the two boxes above it. This section should be used to populate the first indirect entity's BEFORE data. This is an entity below the reporting level. This sub-entity will have portfolios directly reporting to it. The data for this can be found on the EntitiesData tab of the previous day's Excel file. Note that below, in the previous day's data, there are three clusters of rows that have more than one row per set. These are the indirect holdings. Because the portal sums all the indirect and direct BEFORE holdings together, please only include the bottom row of each group. Otherwise, the values will be double-counted.
The completed section after copying BEFORE from Excel sheet row 6 (first indirect entity) will look like this:
Once this section is done, please use the "+ Add Another Repetition" button to create a new dependent entities section to use for the second indirect entity (row 10 on the Excel file above). And then repeat the steps for the last one (row 15 on the Excel document)
Reason for submitting the notification. For each entity, the BEFORE and AFTER data will need to be provided. "Date of the event" will be the position date, as will most likely be the "Date of obtaining information about the event". Please select a Type of event from the drop down that is most appropriate for each entity.
Finally, the financial instruments section. If you hold financial instruments in Poland, you will need to fill this section out as well.
Select the "Applicable" button, and this section below will appear:
Then select the first or second check box below that. Note that these correspond to the ESMA tables 7b1 and 7b2 that you are used to from the Word document.
We recommend you do this one table at a time. Above, we have selected the first box. For table 7b1. FundApps does not yet have the capability to group by Entity and then also by various asset types for a single table calculation. FundApps does not yet have the capability to group by Entity and then also by various asset types for a single table calculation. As a result, we can only provide total numbers by equity but cannot provide granularity on the "Instrument type or name." Clients can either add general descriptions for each entity along with the total numbers or use tables 7b1 and 7b2 from the Word documents to provide more granular detail. We have reached out to the regulator to check on this and will update the User manual if we get better clarification on this section. Unfortunately, given the fact that "Date of expiration of the instrument" is one of the boxes to be completed, clients may have to "Add Another Repetition" to detail every financial instrument for each entity. Here is an example from tab EntitiesFinInst1 - which corresponds to the old table 7b1:
Here are the Word document tables (note these numbers are from different test data)
Picture21.pngOnce the data for the first section (what we used to call table 7b1 in Word) has been completed, the second box can be checked, and it will open an identical-looking section that must be filled out for each entity. This will require the data in the tab EntitiesFinInst2
The last section is the AFTER totals for everything.
Data for these can be found at the bottom of the Main tab on the Excel sheet for the position date.

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