UCITS Rules Summary – Highwire Extensions

UCITS Rules Summary: Your Comprehensive Guide to Key Regulations and Guidelines

Category	Rule ref	Rule	Short Commentary	Override field
Asset Eligibility	P20001	P20001: No Ineligible Assets for UCITS	UCITS must only invest into eligible assets. This extends to Transferable Securities, MMI, CIS, Deposits, Warrants, FDI or Cash. This rule is a high level rule which considers the eligible asset types for UCITS and checks that there are no direct investments into Property or Commodities. This is then supplemented by a range of additional more detailed asset eligibility rules. The rule uses the User Defined Selection of “$_UCITS Ineligible Assets.” This is defined as being any security where the Asset Group is any of the HighWire Asset Groups that should never be held on UCITS (including property, loans, debt issuance, gold, commodities, crypto etc).	Securities / Asset Manual Classification,/ "Is UCITS Eligible Asset"
Asset Eligibility	P20002.1	P20002.1: Securities must be eligible transferable securities - Equities	All securities must be eligible transferable securities. For equities, in HighWire, we assume that this is the case for equities listed on leading stock exchanges. Otherwise, the equity will flag as an exception. You should also expect this for delisted/ suspended / OTCs and private equity. Exceptions can be overridden through the field "is_transferable" is manually set as "True".	Securities / Asset Manual Classification / "Is Approved Transferable security"
Asset Eligibility	P20002.2	P20002.2: Securities must be eligible transferable securities - FI	All securities must be eligible transferable securities. For fixed income, in HighWire, we assume that this is the case for: - Government bonds of leading governments - Fixed income Otherwise, the fixed income will flag as an exception, Exceptions can be overridden through the field "is_transferable" is manually set as "True".	Securities / Asset Manual Classification / "Is Approved Transferable security"
Asset Eligibility	P20002.3	P20002.3: Securities must be eligible transferable securities - CEF	All securities must be eligible transferable securities. For closed-end in HighWire, we assume that the requirements for transferability are met for closed end funds listed on specified exchanges in United Kingdom, United States, Japan, Hong Kong, Singapore, Canada, Guernsey, France. The specified exchanges being XLON, AIMX, XNGS, XCIE, XTSE, XHKG, XSES. This is not based on detailed assessment of the markets, but reflects that listing standards for closed end funds may differ. Otherwise, the closed-end fund will flag as an exception. You should also expect this for delisted/ suspended / OTCs and private closed end funds. Exceptions can be overridden through the field "is_transferable" is manually set as "True". Note: Closed end funds must also meet additional criteria, for which see Rules P20003.2 and P20003.2	Securities / Asset Manual Classification / "Is Approved Transferable security"
Asset Eligibility	P20002.4	P20002.4: Securities must be eligible transferable securities - SP	All securities must be eligible transferable securities. Structured Products encompasses a broad range of products, both on-exchange and OTC. being on-exchange is no guarantee as regards them being "transferable." Our approach is that all structured products will default as being not transferable, other than for a range of structured products that Funds-Axis will have classified as being transferable which includes a range of ETC/ETP giving delta 1 exposure to commodities and traded on the LSE. Otherwise, the structured product will flag as an exception. This includes for structured products issued by the likes of Socgen, Barclays, JP Morgan, Morgan Stanley, HSBC etc. Exceptions can be overridden through the field "is_transferable" is manually set as "True".	Securities / Asset Manual Classification / "Is Approved Transferable security"
Asset Eligibility	P20003	P20003: Closed end funds must be approved for UCITS (regulated / segregated assets)	Closed-ended funds must meet the standard criteria to be eligible Transferable Securities. They must also meet specific additional criteria applicable to closed end funds, in respect of the investment manager having to be regulated and their being segregation of assets in place. This is deal with manually by maintaining the field "Is Approved Closed End Fund"	Manual Data Management / Securities / Asset Manual Classification / Is approved Closed Ended Fund
Asset Eligibility	P20004	P20004: MMI must be approved MMI	MMI must be eligible money market instruments These include that an MMI which is: - “normally dealt in on the money market” - is liquid and - has a value which can be accurately determined at any time. “Normally dealt in on the money market” means (1) has a maturity at issuance of up to and including 397 days; or (2) has a residual maturity of up to and including 397 days; or (3) undergoes regular yield adjustments in line with money market conditions at least every 397 days; or (4) has a risk profile, including credit and interest rate risks, corresponding to that of an instrument which has a maturity as set out in (1) or (2) or is subject to yield adjustments as set out in (3).	Manual Data Management / Securities / Date / Maturity Date Manual Data Management / Securities / Coupon / Next Coupon Reset Date To override: Securities / MMI / Is Approved MMI
Asset Eligibility	P20004.2	P20004.2: MMI must have a maturity of less than 397 days	MMI must have a maturity of less than 397 days. In HighWire, maturity dates default to 31/12/2049 unless provided; this will cause an exception to occur unless the maturity date is provided. If they do not meet this criteria, then consideration can be given as to whether they are eligible transferable securities.	Manual Data Management / Securities / Date / Maturity Date Manual Data Management / Securities / Coupon / Next Coupon Reset Date
Asset Eligibility	P20005	P20005: CIS must be UCITS or equivalent non-UCITS CIS	Where a UCITS invests into another open ended fund (a CIS), that CIS must either itself be a UCITS or it must be another open ended scheme which is equivalent to a UCITS. Within HighWire, a fund invested into will by default be considered to be: - open-ended unless it is specifically flagged as closed-ended - not be equivalent to a UCITS - to have maximum 100% in other CIS	Securities / CIS / "Is UCITS" or "Is UCITS Equivalent"
Asset Eligibility	P20007	P20007: CIS which invest greater than 10% in other CIS. Prohibited	When a UCITS invests into another open ended fund (a collective investment scheme "CIS"), that CIS must restrict it's investment in other CIS to a maximum of 10% of its NAV. This is regardless of whether the CIS into which the UCITS is investing is a UCITS or not. By default, where a new CIS is invested into, the system will show that that CIS can invest 100% in other CIS. This will accordingly cause an exception until the fund invested into is updated to record its maximum investment in other CIS.	Securities / CIS / Max Investment in other CIS
Asset Eligibility	P20008	Deposits must mature within one year or be repayable upon demand	Deposits must have a maturity of less than 12 months or be Repayable Upon Demand. In HighWire, - maturity dates default to 31/12/2049 unless provided; this will cause an exception to occur unless the maturity date is provided. - Repayable on Demand will by default be not set as TRUE	Securities/ Date / Maturity Date or Securities / Deposits / Is Repayable on Demand
Asset Eligibility	P20009	P20009: Deposits must be made with acceptable credit institutions	All deposits must be with acceptable deposit takers. In HighWire, the Deposit Taker uploads against the Holding as the Counterparty. All the Counterparties are set up as Issuers in the Issuer Master. By default all the Issuers are set so that they are NOT acceptable deposit takers. Accordingly by default, we would have a breach of this rule, unless otherwise corrected. We also include Cash within this rule.	Ensure the Deposit Taker (the Counterparty) is populated against the Holding. Then, Issuers / General / Issuer is Approved Deposit Taker
Asset Eligibility	P20010	P20010: FDI must have eligible underlyings	This will include anything that is a UCITS Eligible asset, including equity, bonds and funds that would themselves be UCITS eligible. It will also include, for example, currency derivative, interest rate derivatives as well as derivatives on dividends, volatility, credit etc. This will also include derivatives on approved indices. The index is only eligible where it meets various criteria in respect of being diversified, being an adequate benchmark and being appropriately published, which will include well-known diversified indices. Derivatives that will not be permitted include derivatives on direct real estate and on direct commodities. The rule is written in a way that in some cases it excludes (hence no exception) whole asset types, e.g. interest rate and currency derivatives. For others, it considers the field "Is UCITS eligible Assets" against the underlying security.	To override, check for the underlying security / index that the field Security / Asset Manual Classification / Is UCITS Eligible Asset = TRUE.
Asset Eligibility	P20011	P20011: OTC derivatives must be with acceptable counterparties	OTC derivatives must be with Acceptable_Counterparties. The Counterparty is uploaded via the Holdings file. To upload successfully, the counterparty must be an entity that is set up in the Company Master. In the Company Master, you specify whether the Company is an eligible 5% or eligible 10% counterparty. By default, each Company is set to not be either a 5% or 10% approved counterparty. Hence this will cause a exception unless the counterparty is updated accordingly.	Ensure the Counterparty)is populated against the Holding. Then, Issuers / General / Issuer. OTC Limit
Asset Eligibility	P20012	P20012: OTC derivatives must be capable of reliable valuation	The following two rules substantially overlap. We would except the same range of investments to be passing and breaching for each: P20012: OTC derivatives must be capable of reliable valuation P20012.2: OTC Derivative must be liquid For example, - We don't expect exceptions for very common OTCs including: FFX, interest rate swaps, CFDs on listed equity, leading CDS etc. - We would expect this to flag against Structured products, other than those exchange traded structured products which are auto-classified by Funds-Axis to be UCITS Eligible. This flagging will include exchange listed bi-lateral structured products. The difference is the Overrides fields used to clear the exceptions, as appropriate. For P20012: OTC derivatives must be capable of reliable valuation. we have a field of "Is_Reliable_Valuation". Unless specified otherwise, this is defaults to "False" and hence will breach, until specified otherwise. For P20012.2: OTC Derivative must be liquid, we use the AIFMD Liquidity Classifications and require that this be set as 1 Day or less or 2 to 7 days.	Manual Data Management / Securities / Asset Manual Classification / Has Reliable Valuation also, ensure that Manual Data Management / Securities / Asset Manual Classification / Is Difficult to Price is not set as equals TRUE
Asset Eligibility	P20012.2	P20012.2: OTC Derivative must be liquid		Manual Data Management / Securities / Asset Manual Classification / AIFMD Liquidity
Approved Markets	P20013	P20013: 10% max. in Transferable securities and MMI not on eligible market	There must be less than 10% of the Net Asset Value of the fund in Securities and money market instruments which are not on an eligible market. This will include anything flagging as not being as an exception for not being Transferable. Additionally, at a high level, the Rule will flag for: - Equities not listed on either an EU Regulated market or a market set out n the prospectus - Fixed Income which is not either EU Governments, other governments listed in the prospectus, corporate bonds not on EU Regulated Markets or on bond markets set out in the prospectus - Structured Products, except an EU Regulated market or a market set out n the prospectus - Closed-end funds except those on an EU Regulated market or a market set out n the prospectus - MMI except those which are on an EU Regulated Market or a market set out in the prospectus or are issued by an approved MMI Issuer. There are exceptions for securities where they are securities listing within one year Note, approved MMI Issuer includes where issuer is governments, central banks but also other credit institutions and also where issued by an appropriate body, any securities of which are dealt in on an eligible market. Specific criteria apply. See eligibility criteria are set out at Article 50.1 (h) of the UCITS Directive.	If it is listed check the exchange is populated at Securities / Exchanges / Exchange Name If the Exchange is an EU Regulated market, then check why this isn't being captured in the UDS. If the exchange is listed out in the prospectus, then then check why this isn't being captured in the relevant UDS. For MMI to override, use Issuer / Issuer is Approved MMI Issuer.
Approved Markets	P20014	P20014: Warning: Where unlisted securities are to be listed within 365 days	The UCITS eligible markets rule (P20013) has an exemption for Recently Issued Securities. However, there are criteria to be met including that the listing should be secured within one year of issue date	If it is listed check the exchange is populated at Securities / Exchanges / Exchange Name Otherwise, Manual Data Management / Securities / Date / Issue Date or Listing Date
Asset Eligibility	P20020.1	P20020.1: No investment in Nil and partly paid securities	"Nil-paid" refers to rights attached to a security that are tradeable but which were originally issued at no cost to the seller. We may see that some portfolios have "Rights." These will flag as exceptions. Where the portfolio has purchased the rights, then presumably this will be a breach. Where the rights have been granted by the issuer further to an existing holding, then this would not be a valid breach. In this case, the breach should be closed on this basis.
Diversification - TS	P20026	P20026: UK - Max 10% NAV in Securities & MMI issued by the same Issuer Group	In respect of transferable securities or money market instruments, there can be a max of 10% exposure to any one issuer . We need to aggregate the derivative and non-derivative exposure together. Commitment Method netting applies. The rule operates at underlying Issuer level (underlying issuer group level in the UK). Note: - GOPS are excluded - Covered bonds are excluded - Eligible Index Derivatives are excluded - Derivative such as currency derivatives, interest rate derivatives will be excluded	If it is a Covered Bond, Securities / Asset Manual Classification / Is Covered Bond If it a GOPS, update Issuers / General / Issuers is GOPS If it is an Index Derivative, xx If it is a derivative such as a currency derivative, interest rate derivative, then the UDS will need corrected.
Diversification - TS	P20029	P20029: UK - Max 40% NAV in Securities & MMI where the exposure to the UL issuer Group is greater than 5% NAV	In respect of transferable securities or money market instruments, there can be a maximum of 40% of NAV in aggregate in all the underlying issuer exposures which are greater than 5% NAV. We need to aggregate the derivative and non-derivative exposure together. Commitment Method netting applies. The rule operates at underlying Issuer level (underlying issuer group level in the UK). Note: - GOPS are excluded - Covered bonds are excluded - Eligible Index Derivatives are excluded - Derivative such as currency derivatives, interest rate derivatives will be excluded
Diversification - TS	P20030	P20030: Max 35% NAV in the Securities of any One GOPS Issuer, unless the Issuer is a 100% GOPS Issuer	Where a transferable security is a UCITS Government or Public Security (GOPS), then the UCITS can hold up to 35% of its NAV in that one Issuer. If the prospectus permits, then the UCITS may hold up to 100% in that one GAPS issuer. This rule only applies to GOPS. We need to aggregate the derivative and non-derivative exposure together.	if prospectus permits greater than 35% investment in the GOPS issuer, then this needs reflected in the scheme mandate. Portfolios / Portfolio Mandate / >35% GOPS Issuer
Diversification - TS	P20031	P20031: If Issuer is a 100% GOPS Issuer, Max 30% NAV in any One Issue	If the prospectus permits, then a UCITS may hold up to 100% in that one GOPS issuer. However, there must be a maximum of 30% in any one issue. This rule only applies to GOPS. We need to aggregate the derivative and non-derivative exposure together.
Diversification - TS	P20032	P20032: Max 100% Exposure to any one GOPS Issuer	Where a transferable security is a UCITS Government or Public Security, then the UCITS can hold up to 35% of its NAV in that one Issuer. If the prospectus permits more in respect of that particular issuer, then the UCITS may hold up to 100% in that one issuer. This rule only applies to GOPS. We need to aggregate the derivative and non-derivative exposure together.	Issuers / General / Issuers is GOPS
Diversification - TS	P20034	P20034: If GOPS Issuer holding is >35%, minimum 6 GOPS issues held of any GOPS Issuer	We interpret this as any 6 other GOPS securities, not necessarily of the same GOPS Issuer This rule only applies to GOPS. We need to aggregate the derivative and non-derivative exposure together.	Issuers / General / Issuers is GOPS
Diversification - TS	P20035	P20035: Max 25% NAV in Covered Bonds of any one issuer (Bonds Issued by a Credit Institution with Special Public Supervision)	Where a transferable security is n EU Covered Bond, then the UCITS can hold up to 25% of its NAV in that in the EU Covered Bonds of any one Issuer. Applies only to EU Covered Bonds. Covered Bonds are bonds Issued by a Credit Institution with Special Public Supervision.	Securities / Asset Manual Classification / Is Covered Bond
Diversification - TS	P20036	P20036: Max 80% NAV in Covered Bonds (Bonds Issued by Credit Institutions with Special Public Supervision in which more than 5% is Invested	A UCITS may have a maximum of 80% of its NAV in all Covered Bonds in which more than 5% is invested in any one. This applies only to EU Covered Bonds. Covered Bonds are bonds Issued by a Credit Institution with Special Public Supervision.	Securities / Asset Manual Classification / Is Covered Bond
Diversification - Cash and Deposits	P20037	P20037: Max 20% NAV in Deposits with any one Credit Institution	A UCITS may have a maximum of 20% of its NAV in aggregate Deposits with any one Deposit Taker. We also include cash within this limit. We restrict this to positive cash so that borrowings do not have the effect of reducing the aggregated exposure. In HighWire, the Deposit Taker uploads against the Holding as the Counterparty. Hence, this rule is written against the Counterparty level.	Ensure the Deposit Taker (Counterparty) is populated against the Holding. There is complexity as regards application of the rule to trade or settled cash. See Detailed notes.
Diversification - Cash and Deposits	P20038	P20038: Max 20% NAV in Cash and Ancillary Liquid Assets (Industry approach)	A UCITS may hold "Ancillary Liquid Asset." This is referring to Cash. Cash is separate to deposits. No regulatory threshold is set. However, as a general rule a UCITS should be fully invested rather than be sitting in Cash. Accordingly, as an internal limit we state that cash holdings must be less than 20% NAV, with a warning at 10%. The Irish UCITS rules specifically provide that the UCITS should have max. 10% in ancillary liquid assets.	Ensure the Counterparty is populated against the Holding. There is complexity as regards application of the rule to trade or settled cash. See Detailed notes. Deposits, Margin etc. would not be considered in this rule.
Diversification - CIS	P20040	P20040: Max 20% NAV in a single CIS	A UCITS may invest a maximum of 20% of its NAV in any one other Collective Investment Scheme. This requires us to aggregate together all the investments into different shareclasses of a fund invested into. Accordingly, in HighWire, we write this rule at Issuer level. Note: Most UCITS also restrict their investment in other CIS to an aggregate of 10%. That is a separate rule and covered by P10088: [CIS ]. Max 10% NAV Exposure In any one CIS, which is applied where applicable.
Diversification - CIS	P20043	P20043: Max 30% NAV in aggregate CIS which are not UCITS	The total market value of all CIS which are not UCITS must be less than 30% NAV. Note, the "Is_UCITS" flag will be defaulted to be False, unless set otherwise (either though automated data upload or manually).	Securities / CIS / "Is UCITS"
Counterparty Exposure	P20044	P20044: Max 5% NAV OTC Derivatives with Eligible Counterparties	OTC derivatives must be with Acceptable_Counterparties. The Counterparty is uploaded via the Holdings file. To upload successfully, the counterparty must be an entity that is set up in the Company Master. In the Company Master, you specify whether the Company is an eligible 5% or eligible 10% counterparty. By default, each Company is set to not be either a 5% or 10% approved counterparty. Hence this will cause a exception unless the counterparty is updated accordingly. In these rules rule, we monitor that: - if the counterparty is an approved 5 percent counterparty, that the total counterparty exposure with that counterparty is less than 5 per cent, or - if the counterparty is an approved 10 per cent counterparty, that the counterparty exposure is below 10 per cent. Note we also include margin and collateral in this rule, unless the Margin is set as Risk Free. Note this rule is at the level of the counterparty not the counterparty group	Ensure the Counterparty is populated against the Holding. Then Issuers / General / Acceptable OTC Limit, as either 5% or 10%
Counterparty Exposure	P20045	P20045: Max 10% NAV OTC Derivatives with Approved Credit Institutions
Global Exposure	P19001	P19001 [$_Portfolio ]. UCITS Commitment Leverage. Max 100% NAV	A UCITS (unless using VaR) may have 100% incremental exposure when calculated using the UCITS commitment method. This is also subject to this derivatives usage for investment (and leverage) purposes being disclosed in the Prospectus. Alternatively, the Prospectus may refer to derivatives being used for EPM purposes only, in which case there should be 0% incremental leverage (commitment method).	If the rule doesn’t apply to the portfolio, for example because the portfolio can use derivatives for investment purposes, then disapply the rule and use an alternative rule (e.g. P19002 - 100% incremental commitment exposure instead).
Global Exposure	P19001	P19002 [$_Portfolio ]. UCITS Commitment Leverage. Max 100% NAV	A UCITS (unless using VaR) may have 100% incremental exposure when calculated using the UCITS commitment method. This is also subject to this derivatives usage for investment (and leverage) purposes being disclosed in the Prospectus. Alternatively, the Prospectus may refer to derivatives being used for EPM purposes only, in which case there should be 0% incremental leverage (commitment method).	If the rule doesn’t apply to the portfolio, for example because the portfolio can utilises VAR, then disapply the rule.
Cover	P20048	P20048: Liquid Assets Cover for Derivative Obligations	The sum of the "Liquid_Cover_Required" for derivatives must be less than the sum of the "Liquid_Cover_Available" from assets other than derivatives. In this regard, - for cash settled derivatives, the liquid cover required will be the unrealised loss on the derivative. - Liquid_Cover_Available will include: Cash and deposits but also fixed income and equities, subject to certain Haircuts. - Liquid_Cover_Required will be the unrealised loss on any cash settled derivatives, but economic or notional exposure for physically settled derivatives.	Security / Settlement Type / Is_Cash_Settled = True
Cover	P20049	P20049: Specific Cover for Derivatives Obligations	Physically settled short derivatives on underlying which are not highly liquid require physical cover. In other words, the portfolio must hold the actual underlying asset. If a derivative is erroneously showing as requiring Specific / physical cover, then this can be corrected by manually updating the derivative to specify either that: - it is Cash Settled; or - the underlying is Highly Liquid.	Security / Settlement Type / Is_Cash_Settled = True
Asset Eligibility	P20050	P20050: No Physical Short Selling UCITS	UCITS are not permitted to physically short sell. This relates to equities, bonds, MMI, funds, structured products. This will not apply to derivatives and cash / borrowing.
Borrowing	P20052	P20052: 10% max. in borrowings (traded basis) (with netting at currency level)		Consider further the use of trade or settled balances. Consider the approach to netting.
Borrowing	P20054	P20054: Borrowings must be temporary - 90 days continuous	UCITS borrowing must be on a temporary basis and not persistent. This includes that there should no period of borrowing exceeding three months, whether in respect of any specific sum or at all. This applies to each account balance individually.	For minimal negative balances, e.g. -£100, consider setting a de-minimum amount: Organisation / Manager / Borrowing de-minimis. Otherwise, consider further the use of trade or settled balances.
Borrowing	P20055	P20055: Borrowings must be temporary - 90 days in 180	UCITS borrowing must be on a temporary basis and not persistent. In addition to the 90 day continuous rule, this includes that there should no persistent borrowing. Our standard approach is to monitor for as more than 90 days in 180.	For minimal negative balances, e.g. -£100, consider setting a de-minimum amount: Organisation / Manager / Borrowing de-minimis. Otherwise, consider further the use of trade or settled balances. Consider the approach to netting.
Consolidated Exposure	P20059	P20059: Consolidated Exposure (excl. Covered bonds & GAPS) must be less than 20% NAV	Here we aggregate the exposure to any one underlying issuer group, through - transferable securities and money markets - derivatives that give exposure to the same - cash and deposits - any Counterparty exposure to the same, including via OTC derivatives and margin posted. Note: In HighWire, cash and deposits as well as OTC derivatives and margin are posted via a "CPProxy" adjustment and hence should not be visible as individual contributors. The following should not be included: - GOPS - Covered Bonds - Open ended Funds - Index derivatives (except for Counterparty element) - Derivatives on Government Bonds (except for Counterparty element)	If it is a Covered Bond, Securities / Asset Manual- Classification / Is Covered Bond If it a GOPS, update Issuers / General / Issuers is GOPS If it is an Index Derivative, check for the underlying index that it is flagged as TRUE in Security / Asset Manual Classification / Is UCITS Eligible Asset.
Consolidated Exposure	P20060	P20060: Consolidated Exposure (incl. Covered bonds but excl. GAPS) must be less than 35% NAV	Here we aggregate the exposure to any one underlying issuer group, through - transferable securities and money markets - derivatives that give exposure to the same - cash and deposits - any Counterparty exposure to the same, including via OTC derivatives and margin posted. Note: In HighWire, cash and deposits as well as OTC derivatives and margin are posted via a "CPProxy" adjustment and hence should not be visible as individual contributors. The following should not be included: - GOPS - Open ended Funds - Index derivatives (except for Counterparty element) - Derivatives on Government Bonds (except for Counterparty element)	If it a GOPS, update Issuers / General / Issuers is GOPS If it is an Index Derivative, check for the underlying index that it is flagged as TRUE in Security / Asset Manual Classification / Is UCITS Eligible Asset.
Cross-Investment	P20061	P20061: No Investment in CIS of the Same Umbrella	A UCITS may not invest in another CIS within the same Umbrella (legal entity / ICVC/OEIC/SICAV). This rule works by comparing the fields: Organisation/LegalEntity.LEI and the Security.umbrellacode. Where they are identical, then the calculated field of "instrumentisumbrella" will be equal to TRUE and will flag an exception.	Security / General / Umbrella Code
Cross-Investment	P20062	P20062: No investment in another sub-fund of the same Manager, unless permitted in prospectus	A UCITS may not invest in another CIS of the same manager, unless permitted in the prospectus.
Ownership / Significant Influence	P20070	P20070: Cover all: max 10% of security issued capital	This is an optional, non-regulatory, rule that should serve as a "cover-all" for the Significant Influence and Concentration Rules. The regulations relate to towner of the issuer voting shares / non-voting shares./ debt in issue / mmi in issue. This issuer level denominator data can be hard to find. In contrast, this rule operates at security level having regard to the security level issued capital. If the rule passes at security level, then the regulatory rules also be passing at Issuer level. Exposure via derivatives is not included. Government Securities are not included.	If it a GOPS, update Issuers / General / Issuers is GOPS If result is showing a massive percentage, e.g. 100000%, then this is because the issued capital data is missing and needs manually researched.
Ownership / Significant Influence	P20071	P20071: Ownership = Manager: Scheme: 20% max. of voting shares per single issuing body	A Manager, across all its UCITS, may own a maximum of 20% of all the voting rights issued by any one Issuer. The rule considers, at a Manager level, the voting rights held as a percentage of the total voting rights in issuance. System set-up Against each security, there is a fields for Voting Rights per share" - the number of votes that every share is entitled to. Votingshares are those where votes per share is not equal to 0. To support this, this field is defaulted to 1 for any securities that we believe have voting rights but where the amount of votes per share is unknown. This is defaulted to 0 for any shares that we believe are non-voting shares. The denominator is the Issuer_Total_Voting_Rights)Issued. This is maintained against the Issuer in the Company Master. Where Issuer_total_voting_rights_issued is not known, the denominator will default to 1, resulting in large erroneous breaches, e.g. 99999%
Ownership / Significant Influence	P20073	P20073: Ownership - Umbrella: 10% max. of non-voting shares issued by single issuing body	At a legal entity level, a UCITS may hold a maximum of 10%of the debt is issue of any one debt issue. The relevant denominator is the field Issuer.Total Non-Voting Shares in Issuance. This can be hard data to sources. As a fall-back, we will populate this with the sum of the issued capital of all the Issuer non-voting shares that we are aware of. This can be overridden as need be.	If the shares have voting rights, then the votes per share field should be updated.
Ownership / Significant Influence	P20075	P20075: Ownership - Umbrella: 10% max. in Debt Securities issued by a single issuing body	At a legal entity level, a UCITS may hold a maximum of 10%of the debt is issue of any one debt issue. This excludes Governments (as opposed to EU GOPS) . The relevant denominator is the field Issuer. Debt in Issuance. Breaches are common with structured products. For a number of structured Products Issuers, we upload a figure of 999,999,999 for the issuer debt in issue. This will prevent any breaches flagging. Instead, we then monitor structured products at a security level in the P20070 Cover All Rule.	If it a GOPS, update Issuers / General / Issuers is GOPS
Ownership / Significant Influence	P20077	P20077: Umbrella: 10% max. in MMI issued by a single issuing body	At a legal entity level, a UCITS may hold a maximum of 10%of the debt is issue of any one debt issue. This excludes Governments (as opposed to EU GOPS) . The relevant denominator is the field Issuer.Total MMI in Issuance. This can be hard data to sources. As a fall-back, we will populate this with the sum of the issued capital of all the Issuer MMI that we are aware of. This can be overridden as need be.	If it a GOPS, update Issuers / General / Issuers is GOPS
Ownership - CIS	P20078	P20023: Max 25% of the units issued by any one CIS (portfolio)	We monitor this at the level of the shareclass invested into by considering the quantity held as a percentage of the units / shares in issue of that shareclass. If the rule is passing at this level, then it will also pass at the level of the quantity held as a percentage of the units in issue of the fund invested into (being all shareclasses). Where the shares in issue of that class are not known, we will use a default denominator of 1. This will result in very large exception percentages. In this case, the shares in issues needs sourced and updated. The rule applies to open ended funds only. Closed end funds may be erroneously caught in the rule, unless they are marked as being "Isopenended" = False. Alternative approach Strictly speaking, when considering the investment in the CIS invested into, we need to look at the total holding in that CIS, not at each unit / share classes separately. In this case, it would make no sense to look a the quantity of units / shares issues, as the different units/shares in issue may have different prices. Instead, we would need to aggregate on value held as a percentage of the funds total NAV. From a system perspective, this would be marketvalue as a percentage of issue.market capitalistion.	If Closed_end fund is appearing as an exception, then Security /"Isopenended" = False. If denominator is missing, then source the shares in issue of that shareclass. If it is a valid exception at the level of investment into the shareclass, then consider whether it is an exception at a fund invested into level, being the total value of investments into that fund / total Nav of that fund.