Managing External Disclosures
Managing External Disclosures Overview
Some jurisdictions have events that are not threshold based, which require the investor to make a disclosure. 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 modeled in our rules, we have introduced a mechanism that allows users to record these disclosures; for these external disclosures to be used in subsequent calculations and for an audit to be kept of these disclosures.
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.