You can set disaggregation in FundApps
For disaggregation (i.e. aggregation exemptions), we allow our clients to set logic between entities in their corporate tree where they have either confirmed that the facts of their firm satisfy the disaggregation criteria in a given jurisdiction or compliance regime (i.e. rule) within a jurisdiction. For most clients, this usually entails obtaining confirmation from their internal legal or compliance departments or securing documented disaggregation agreements with a regulator directly.
Clients are responsible for deciding whether they meet exemption criteria
Some shareholding disclosure regimes might require (or allow) a signed agreement with the regulator and for others, holding assurance of certain facts related to their corporate tree might suffice. This varies by jurisdiction. If a client is interested in disaggregation, we ask that they thoroughly review the aosphere memo section in each jurisdiction (usually in a section entitled "Exemptions from the aggregation principle" or similar) where they seek this and consult with their legal or compliance group on the matter. In the UK, for example, see sections A.2.6 and more saliently A.5.10.
FundApps can allow functionality, but cannot advise on disaggregation
FundApps cannot advise on if a client might disaggregate certain parts of their corporate tree for purposes of shareholding disclosure but allows the functionality to do so if our clients have confirmed that their analysis aligns with the disaggregation rules of a given regime/jurisdiction.
How to set up disaggregation in FundApps
If you would like to set up disaggregation, please contact your CSM, who will walk you through the process of approving this in your environment and uploading the CSV file.
Your CSM will help sense check the backing for disaggregation and request from you a CSV file containing the disaggregation. Please provide the CSV file in the format linked to this page.
How to Fill In the CSV file
|Column in CSV||Description||Example|
|Name||Description of this type of Disaggregation, to be set by client||Belgian Regulator Exemption|
|Country||Specifies relevant jurisdiction by two digit country code||BE|
|Labels||Rule label, you can choose from labels such as "Major Shareholding", "Takeover", or "Short Selling" Corresponds with label on rule.
Choose to populate either Labels or Rules.
|Rules||Rule code, which specifies the rule that should adhere to disaggregation. Corresponds with Rule Code on rule page. Choose to populate either Labels or Rules.||MajorBE|
|Entities||Specify the entity after which the aggregation should stop, assuming it rolls upwards. Use the PortfolioID from the portfolio file.||Entity 2|