How to Raise a Query Disputing a Rule or Regulatory Interpretation

Do you have questions about how we’ve coded rules in relation to aosphere's wording or perhaps, disagree with certain sections of their memo? This is your guide to resolving such concerns. We are here to assist you if there seems to be a misalignment between your understanding and our interpretation or aosphere's.

Please ensure your request includes the following crucial details. In cases where your request doesn't adequately specify the disputed issue or lacks the necessary supporting sources, our first interaction will likely request this essential information.

If You disagree with how rules are coded in relation to aosphere wording:

  1. What part of the rule coding/results do you disagree with, and what is your view?
  2. Which sections of the aosphere memo support your view?
  3. What (if any) official regulatory correspondence, regulation, or evidence from industry practice relates to the issue? 

If you disagree with sections of an aosphere memo:

  1. Which section(s) of the memo do you disagree with?
  2. What is the summary of your alternative view?
  3. What is the legal reasoning based on the memo behind your alternative view?
      • Please also provide the sources that you are deriving the legal reasoning from.
      • While market practice can inform reasoning, our rules align with the aosphere memos. Practically, this means that legal reasoning is required for us to consider any changes to our interpretations of rules.
      • Consider whether any conflicting legal advice or responses from regulators have been provided based on facts of a specific circumstance. We still welcome such information, but please outline any assumptions the legal advice or response was based on.

Note: If the memo is ambiguous, FundApps may have taken a more "conservative" interpretation of the rule or made assumptions to automate certain considerations; check the rule's Explanation tab for details.

Example:

Hello FundApps support,

We would like to highlight a concern related to the regulatory interpretation made in Rule Name: Major: Indonesia. Section A.1.1 of the Indonesia memo states that:

The rule in FundApps reflects this consideration, but we’ve recently received legal advice that seems to contradict this section. In particular, subsection (a) of the memo states that “x” while the following email from local counsel states “y.”

Would you help us understand if there is a conflict and potentially raise this with aosphere?

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