Raising a Rule or Regulatory Query
When raising a query relating to the regulatory interpretation, please provide information for each of the points below. Providing this information helps us understand the issue and provide you with the best answer. It is very likely that if not provided, we will follow up with these questions as the first step in resolving these kinds of queries.
If you disagree with how rules are coded in relation to Aosphere wording:
- What part of the rule coding/results do you disagree with, and what is your view?
- Which sections of the Aosphere memo support your view?
- 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:
- Which section(s) of the memo do you disagree with?
- What is the summary of your alternative view?
- 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 are designed in line 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 has 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 have made assumptions in order to automate certain considerations - check the Rule Explanation for details.
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 Rapptr 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?