Our software automatically handles the slightly different XML format used by the FCA’s RegData.
The FCA’s RegData uses different question numbers than the ESMA. Any ESMA question numbers are automatically cross-referenced to FCA question numbers by our software.
The FCA wants reports over slightly different regions than the ESMA. Matterhorn strives to be able to use the same input data for reporting to multiple countries. To accommodate this, the software automatically reports data in the corresponding FCA region when reporting to the UK.
| Postions on our template with Region (AIF 78-93): | And Currency (AIF 128): | Are reported to the UK as: | Change |
|---|---|---|---|
| Africa | Africa | No | |
| Asia and Pacific (other than Middle East) | Asia and Pacific (other than Middle East) | No | |
| Europe (other than EEA) | GBP | UK | Yes |
| Europe (other than EEA) | Non-GBP | Europe (other than UK) | Yes |
| Europe (EEA) | Europe (other than UK) | Yes | |
| Middle East | Middle East | No | |
| North America | North America | No | |
| South America | South America | No | |
| Supranational / multiple region | Supranational / multiple region | No |
The FCA’s RegData has a validation that can cause rejection of valid data for very small aggregated value percentages. The answers stated below mention thresholds of 0.1% and 0.5%. Our software uses a threshold of 0.5% because we found rejections using 0.1%.
FCA’s RegData Error Message: “Conditional: The ratio between Principal Exposure Aggregated Value Amount and Percentage must be consistent for all exposure entries”
The ratio between Principal Exposure Aggregated Value Amount and Percentage must be consistent for all exposure entries.
Very small aggregated value percentages (less than 0.5% of AUM) may cause rejection of otherwise valid data. This is because the rounding error introduced by the mandated 2dp precision becomes significant when back-calculating the denominator for validation purposes for very small percentages. This issue can be avoided by omitting any lines for aggregated values this small because 0.5% of AUM can neither be described as ‘Principal’ nor ‘Most important’ replacing them with ‘NTA’ or ‘NTA_NTA’ blank entries as appropriate - this is entirely legitimate and within the spirit of the question. Please also see the below calculation for an example of how to calculate this.
b) Principal Exposure and Most important portfolio concentration aggregated value validation
(i) Very small aggregated value percentages (less than 0.1% of AUM) may cause rejection of otherwise valid data. This is because the rounding error introduced by the mandated 2dp precision becomes significant when back-calculating the denominator for validation purposes for very small percentages.
(ii) This issue can be avoided by omitting any lines for aggregated values this small, replacing them with ‘NTA’ or ‘NTA_NTA’ blank entries as appropriate. Because 0.1% of AUM can neither be described as ‘Principal’ nor ‘Most important’ this is entirely legitimate and within the spirit of the question.
The FCA’s RegData has a validation that causes rejection of Private Equity funds (AIF Question 57 is “PEQF”) without any Dominant Influence records. In that case, our software automatically adds a dummy DOMINANT_INFLUENCE record with a company name “Not Applicable”.
FCA’s RegData Error Message: “Conditional: Dominant influences should be specified for private equity funds”
The FCA has a few different Sub-asset types than the ESMA (only concerning Sovereign bonds). We are working on automatically converting them. It is not done yet, so please give us a call if this concerns your fund.
Please contact us at support@matterhorn-rs.com or +31 85 401 8256.
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