Regulator-specific, confidential exemptions
You may have noticed both the "IsAllowedRuleExemptionClient" and "ExemptFromRuleIDs" properties in some rule versions and wondered what this does, or if this section of code is excluding anything important from your results.
The short of it is that this will have no effect on rule results, unless you are a part of a firm that has very specific agreements with regulators which amount to exemptions for certain positions, and your firm has worked with FundApps confidentially to turn this functionality on. This rule code does not have an effect unless FundApps has configured it to be on via the property IsAllowedRuleExemptionClient.
But does this mean that FundApps has new coding for an exemption outlined in an asophere memo and should that apply to me?
No. The use of the ExemptFromRuleIDs functionality relates to very specific cases. If you are interested in regulatory exemption frameworks, we would be happy to discuss that with you separately but normally we ask that the jurisdiction for such cases is first found in the asophere memos.
What this rule feature is for:
- When a client has made a specific agreement with a regulator about excluding certain positions from a regime/rule
- When the application of regulator and regime-specific exemptions can be flagged by the client on an asset-by-asset basis. The regulator-agreement might apply to a set of assets with certain characteristics but the client would be responsible for a tagging all assets (via a asset-level, or position level property) that should be excluded
- Clients who have discussed the regulator- specific exemption with FundApps in depth to ensure that it meets the criteria specified
What this feature is NOT for:
- Regulatory exemption frameworks described to some degree in the aosphere memo (e.g. market maker exemptions)
- Exemptions which are not specific to unique types of holdings.
- Exemptions for which the exclusion could apply to many type of holders based on criteria defined in regulation
Note: Please note that since FundApps seeks to maintain a single rule set for the industry, our general approach to coding regulatory exemptions is not to simply use the functionality described in this article (which is for very specific use-cases). If any of our clients are interested in a regulatory exemption, we ask that you contact us to discuss the precise nature of the exemption and appealing to aosphere's description of the exemption framework in the memo. Requests for additional functionality in rules to handle exemptions are handled similarly to other rule enhancement requests. We would want to understand the importance of it for your firm, the nature and scope of the exemption, and to assess it in light of other rule enhancement requests from our client community.