Managing External Disclosures
Some jurisdictions have disclosable events that are not threshold-based. These "external disclosures" are not captured in our service currently as they do not relate to thresholds, previous disclosures, or data clients send to FundApps.
Given that these events are not currently modelled in our rules, we have introduced a mechanism that allows users to record these disclosures.
This will allow for these external disclosures to be used in subsequent calculations and for auditing.
As opposed to fixed thresholds, some rules are based on the last disclosure value, and a subsequent disclosure would need to be filed when the position moves a certain amount past the last disclosed value.
Without the ability to record an external threshold disclosure in the system, the last disclosed value will be based on an earlier threshold disclosure and not the external requirement (e.g., name change, address change).
FundApps now allows clients to capture the external disclosures for specific rules where this is required. Future disclosure alerts would need to be based on the external disclosure as an anchor.