Some disclosure regimes apply differently to different types of investors. For example, the major shareholding regime in the UK applies differently depending on whether the investor is a UK Investment Manager or not. In that specific case, the thresholds for a major shareholder are lower for non-UK Investment Managers.

FundApps distinguishes between the various applications for specific disclosure regimes via the portfolio property CompanyType. It is an important property to set as it determines which set of rules will run against the uploaded positions. Please note that it is possible to have more than one CompanyType set for a given entity, for example:

The determination of which rules to run happens in the pre-condition of a rule, where the value of the CompanyType property is used as the input.

Not all disclosure regimes worldwide distinguish between different company types. The jurisdictions that do are Canada, the United Kingdom, the USA, Italy, South Korea, and South Africa. Please find below a description of the valid CompanyType values and their impact on setting these.

To be considered for every Entity and Portfolio. This confirms if the entity (or portfolio) is an eligible institutional investor (EII) per Canada's rules. EIIs include (for example) Canadian financial institutions, banking or insurance entities regulated and incorporated in the United States or Japan, credit institutions licensed in France, Germany, Italy or the UK, or an investment manager licensed in Canada, Japan, the United States, France, Germany, Italy or the UK. If the entity or portfolio is an EII, include "AMRS" as a value in its CompanyType. Setting this means the entity or portfolio uses the Alternative Monthly Reporting System ('AMRS') procedure and not the Early Warning Report. Before declaring this value, please ensure that section A.3.1.2, starting "An EII for these purposes means:..." of the Canadian aosphere memo, is read and understood.

One must assess whether an entity is a direct " parent" of a FundApps portfolio and whether it meets the criteria referenced in the memo. One must also assess whether any entity controls, fully or partially owns, or is otherwise affiliated with the direct parent as an EII.

FundApps will evaluate each entity's and portfolio's obligation with respect to its own status, which aligns with memo section A.7.2.

Relying on determining EII (and declaring "AMRS") is not a requirement but an exemption framework. In cases of uncertainty, consider entities or portfolios as non-EII, which means AMRS should not be stated.

To be considered for every Entity. This stands for a UK Investment Manager, EEA investment manager, or non-EEA investment manager equivalent. See the UK aosphere memo section A.6.2 for the precise definition before selecting this value. This allows all EEA investment managers and non-EEA investment managers provided that they can lawfully manage those investments in a non-EEA State and that if they were to manage their investments in the UK would require a Part 4A permission, to disclose at the EU minimum thresholds of 5% and 10% and not the lower 3% with 1% incremental thresholds that would otherwise apply for holdings in UK issuers. It is defined in the UK regulatory note.

For the MajorUS rules related to section 13, the default regime that will run is 13D (rule: MajorUS - 13D), unless you can confirm that all entities in the aggregation tree in FundApps meet the requirement of either of the following categories listed here (in order of increasing stipulations). For example, if entities meet the US-QII requirements, then declare US-QII. If they only meet the US Passive Investor requirements but not QII, then declare USPassiveInvestor.

Note that since FundApps currently supports the case where one filing type is used for the whole company which means that all entities should be set with the same value, not a mix.

To be considered for every Entity and Portfolio. This ensures FundApps invokes the 13G Passive Investor version of the Section 13 rules. If your firm's entities are US QIIs (see above), then use the selection US-QII instead. If an entity is deemed to be a "passive investor" (defined in Section 240.13d-1(c) of the Securities Exchange Act of 1934), then include this value. See the US aosphere memo Section 1.7(b)(iii) and 7.2(c) for further detail on how to determine if your entity(s) are considered as "passive investors."

If an entity/portfolio is a QII as defined by Section 240.13d1(b)(1)(ii)(A)-(K) of the Securities Exchange Act of 1934 (excluding 240.13d1(b)(1)(ii)(G), which is covered below with use of the value US-QII-Parent) this CompanyType value should be applied.

To be applied to any Top Entity which is a parent of a QII, as stated above. As defined in 240.13d1(b)(1)(ii)(G), an entity/portfolio that is a QII is owned by, managed by, or voting rights held by an entity (its parent/control person entity), the parent can also be a QII as long as the parent itself does not directly hold, or its subsidiaries or affiliates (that are not QIIs) do not, directly and indirectly, hold, in aggregate, more than 1% of the securities of the subject class. If the US-QII-Parent value is stated for an entity, FundApps applies a monitoring rule to determine whether the parent entity breaches this condition for a given share class. Please note that the US-QII-Parent value should only be used for the Top Entity since the monitoring rule only runs at this level. See the US aosphere memo and section 240.13d-1(b)for details. Additionally, for the monitoring rule to work effectively, US-QII must be applied to the portfolios of a US-QII entity. Please note: If US-QII, US-QII-Parent or USPassiveInvestor are not provided, FundApps applies the 13D rule.

To be considered for every Entity. This is to confirm the entity (and its controlling entities) are equivalent to an Italian/European asset manager/financial intermediary. This would apply to a non-EU asset manager if it would be subject to similar regulations if it had been set up in Europe. Before declaring this value, please ensure that section A.6.16 of the Italy aosphere memo is read and understood.

For entities that are direct "parents" of a FundApps portfolio, one must assess whether they meet the criteria referenced in the memo. For any entities that control or partially own the direct parent entity, one must also assess whether they can rely on this exemption. The memo notes that this must be assessed case-by-case if the controlling entities are not confirmed to meet disaggregation requirements.

In all cases, this value should only be used if all entities are confirmed to meet the requirements and must be set (consistently - do not mix entities with ITFM and without) on all entities in the aggregation tree. If not, this value should not be used for any entities as it is not required (i.e. it is an exemption).

To be considered for every Portfolio. This confirms the portfolio is: 1) NOT defined as (or managed by) an institution" defined precisely in Section 1.1.2(a) of the South Africa aosphere memo, and 2) NOT a Section 24(d) Person (which is "a person who buys or sells listed securities in order to: (i) give effect to a reconstruction of a company or group of companies by the issue or reallocation of shares, or a take-over or an amalgamation, or (ii) effect a change in control over management or business of the company.")

It is very likely that including this value (NotZA) would be prudent unless you have specific portfolios or legal entities organised under these laws in South Africa (and meet the above criteria).

Under the FMA regime, a non-South African financial institution could still be required to disclose in very specific circumstances. However, FundApps will not consider those specific circumstances if "NotZA" is set as a CompanyType.

To be considered for every Entity and Portfolio. This ensures FundApps invokes the Passive Investor version of the Korean 5% rule. If a top entity or portfolio is deemed to be a "passive investor" (whose equity ownership purpose is not company management), then include this value. See the Korean aosphere memo (section A.1.4), or check this guide from the Financial Supervisory Service for further details on "passive investors."

To be considered for every Entity and Portfolio. This excludes entities and portfolios from the 'Major: US - Section 16(A) - Insider - Precondition' and 'Major: US - Section 16(A) - Insider - Issuer' rules that are not deemed to be beneficial owners under section 16(a) in the US. For more information on the definition of beneficial ownership under section 16(a), please refer to the aosphere memo section B.1.6 or this guidance note.

To be considered for every Entity and Portfolio. This confirms if the entity acquires securities in the ordinary course of business and is a broker, bank, or other institutional investor of a type specified in SRC Rule 18.1.3 (Section 1.4 of the Philippines aosphere memo). Setting this means the entity is eligible for the less onerous ‘Short SEC Form 18-AS’ disclosure and not the ‘Long SEC Form 18-A’.

This applies to co-holders (in terms of the Japan regime), who are Concert parties: co-holders in this arrangement are those that have jointly agreed to transact or vote (most likely when the parent only has a minority of the voting rights in the subsidiary). This excludes Concert Parties from the mandatory 0.1% exemption.

To be considered for every Entity, including the Top Entity. The majority of our clients are co-holders using the Controlled Undertaking structure, as opposed to the concert parties structure. Read more about this exemption for the Major: Japan rules here.

Please note that FundApps does not fully support an entity aggregation hierarchy where entities/portfolios have mixed company types. For example, if you have both UKIM and non-UKIM entities within your structure, we recommend not using the tag at all to be most conservative. If such scenarios apply to you and you'd like to discuss them further, please reach out to your CSM or FundApps Support.