Rules Testing – Test Script (Rule 11 – Rule 33)

Rule 11: 10% max. in securities to be listed within one year, excl. 144A securities

This rule is a caveat to the Max 10% in unapproved securities rule. A UCITS can have ten percent in securities to be listed within one year, excluding 144 A securities
The rule relies on identification of the listing date and looks the securities whether the days to be listed is between 0 and 365.

Whether a security is a 144 can be uploaded from market data or can be set manually in the Debt Master.

	Testing performed	Test completed Satisfactorily	Notes
1	Review the rule text and confirm that it is properly included those instruments where the to be listed date is within 365 days
2	Test the impact of marking a stock, in the Debt Master, as being a 144A security. Test that breach and pass results occur as expected.
3	Download a Governance Report that shows all instruments where the listing date is in the future and identifies all 144A securities also. Check the stocks appearing on the report look appropriate. Test that the identification of 144A securities looks reasonable.

Rule 12: 20% max. of voting shares per single issuing body

This rule considers the voting shares held and compares this to the voting shares outstanding of the issuer.

This rule applies at the Manager level

Within FundWare, if it is not known whether a share is voting or non-voting, it defaults to non-voting – causing the 10% threshold to apply rather than the 20% threshold.

By default, common stock will be set up to be voting and other equity will default to be non-voting. By default, there is 1 vote per share.

	Testing performed	Test completed Satisfactorily	Notes
1	Review the rule text and confirm: That the Rule applies at Manager level The rule considers equities with voting shares That the breach limit is set at 20%
2	Check the Governance report on voting shares to identify any voting shares where the votes per share is not set at 1.
3	Test that when the attribute against an equity to specify whether it is voting or non-voting is changed, that the equity moves to be considered in Rule 12 or Rule 13 as appropriate.

Rule 13: 10% max. of non-voting shares issued by single issuing body

This rule considers the non-voting shares held and compares this to the non-voting shares outstanding of the issuer.

This rule applies at the ICVC level.

Within FundWare, if it is not known whether a share is voting or non-voting, it defaults to non-voting – causing the 10% threshold to apply rather than the 20% threshold.

By default, common stock will be set up to be voting and other equity will default to be non-voting. By default, there is 1 vote per share.

	Testing performed	Test completed Satisfactorily	Notes
1	Review the rule text and confirm: That the Rule applies at ICVC level The rule considers equities without voting shares That the breach limit is set at 10%
2	Check the Governance report / holding reports to confirm that common stock is being set by default as having voting rights and that other shares are set to not have voting rights.
3	Test that when the attribute against an equity to specify that it is has voting shares that the equity moves to be considered in Rule 12 rather than Rule 13.

Rule 13: 10% max. of non-voting shares issued by single issuing body

This rule considers the non-voting shares held and compares this to the non-voting shares outstanding of the issuer.

This rule applies at the ICVC level.

Within FundWare, if it is not known whether a share is voting or non-voting, it defaults to non-voting – causing the 10% threshold to apply rather than the 20% threshold.

By default, common stock will be set up to be voting and other equity will default to be non-voting. By default, there is 1 vote per share.

	Testing performed	Test completed Satisfactorily	Notes
1	Review the rule text and confirm: That the Rule applies at ICVC level The rule considers equities without voting shares That the breach limit is set at 10%
2	Check the Governance report / holding reports to confirm that common stock is being set by default as having voting rights and that other shares are set to not have voting rights.
3	Test that when the attribute against an equity to specify that it is has voting shares that the equity moves to be considered in Rule 12 rather than Rule 13.