MAS, the Singaporean securities regulator have released the implementation details for Short Position Disclosures and the the reporting requirements come into effect from 1st October 2018.

Singapore reporting will be available through DisclosureWise. Salient features include:

• Automatic market value calculation
• Net held percentage calculation based off the latest shares outstanding figures
• Smart reminders to ensure nothing is missed
• Automatic short disclosure submissions to MAS
• Acknowledgement capture and storage

DisclosureWise™ Operations Team work around the clock to ensure that submissions are delivered on time and with guarantee. With team monitored submissions, this is readily done. With certain channels such as FIX, delivery confirmation is provide by the protocol and we capture that.

However, some regulators rely on email submissions. The problem is that email as a technology is prone to delivery failures of all kind. It is just not a protocol which was designed with a transactional nature which we are so accustomed to in financial technology systems.

So with emails, we have to go one stop further and ask the question "how do we make 100% sure that these emails are delivered to the regulator?". To that end, we have implemented an industrial strength, guaranteed email solution. It means that emails are no longer free of cost for us as it is a commercial service, but it means that we can be assured that our submissions to the regulators are always delivered and on time, even when using the tired old protocol which is email.

DisclosureWise™ email submissions are then monitored by our team to ensure delivery. Because follow up is the foundation stone of operational excellence.

One of the known unknowns in calculating correct holdings percentages is the problem with unlisted shares. A large number of companies have multiple classes of shares - most of these will be listed on stock exchanges but certain classes will not be. Commercial market data vendors including your go to terminal only provide the shares outstanding data on listed classes.

This caused us a fair bit of issue in earlier days of product operation. Routinely we would have holding numbers which had to be re-worked because market data vendors would not supply the total shares outstanding figures.

We had to branch into data and research our own. Now we find the shares outstanding data ourselves to ensure that the results are 100% spot on all the time. Our 24 x 7 Operations team do this, trawling through reports, announcements, and regulatory agency updates.

It is safe to say that this particular point is a major plus for utilising a service such as DisclosureWise™.

DisclosureWise provides a single platform for reporting Short Sale disclosures in Australia, Hong Kong and the European Union. All the users have to do is submit the following information to DisclosureWise:

• ISIN code
• Short quantity
• Trade date

Our Short Sale disclosure platform will then apply different processing and monitoring rules and submit positions to the regulator automatically. Following is a matrix summarising these rules:

DisclosureWise are pleased to announce that numerous leading hedge funds have now started automatic disclosures to 17 jurisdictions within EU. These investment advisors include:

• Dialectic Capital
• Eminence Capital
• Sunrise Partners
• Oxford Asset
• Linden

Unlike Australia and Hong Kong, the European Short Disclosure regime has various thresholds at which disclosure requirements kick in.

First of all, lets define Net short percentage figure. Once the position holder has arrived at a Net figure, taking into account all long and short positions in the cash instrument and then netted them against the deltas of derivative or secondary instruments, they can divide the same by the total outstanding shares of the company.

Now if the Net short percentage figure exceeds 0.2%, the position must be notified. If the position falls below 0.2 subsequently it must be notified. If the position breaches any 0.1% increments upwards or downwards from that threshold, it must be notified. So 0.3%, 0.4%, 0.5% are all reportable thresholds for upwards or downwards breaches.

If the position exceeds 0.5%, the position must be publicly disclosed. And then it must be disclosed again if it falls below 0.5%. And as with private notifications listed above, it must also be disclosed at 0.6%, 0.7%, 0.8% ad infinitum, on upwards or downwards breaches.

The European securities regulator ESMA have defined new Short Disclosure Rules which come into effect from 1st November 2012. DisclosureWise platform provides complete automation of European Short Disclosure for reporting to the regulators in leading European markets:

• Calculation of thresholds based on the latest adjusted issued capital figures
• Determine whether a position has increased by 0.1%  since last reportage and report accordingly
• Ability to automatically report the last notification date for a position in the same issuer
• Handling of Public Holidays across 29 member states of the EU
• Filtering out the list of non-reportable stocks as per the regulator notifications
• ISO compliant country codes and date time formats
• Automatic fax confirmations to the regulators where required
• ISIN and Issuer Name validation
• Industrial strength encryption and auditing
• Automated submissions to the regulators
• SFTP, Web Service or Portal based submission
• Rolling Submissions functionality
• Around the clock support

The same file may contain the Australian, Hong Kong and European Short Positions as well, or these can be submitted separately.

Contact Us for detailed information and how we can help alleviate operational risk and meet your compliance obligations.

Our DisclosureWise platform provides complete automation of Hong Kong Short Disclosure for reporting to the SFC:

• Automatic filtering of stocks based on the SFC reportable list
• Automatic market value calculation
• Handling the Weekly or Emergency Daily reporting automatically
• Industrial strength encryption and auditing
• Automated submissions to the SFC
• FX rates translation
• SFTP, Web Service or Portal based submission
• Rolling Submissions functionality

The same file may contain the Australian Short Positions as well, or these can be submitted separately.

Contact Us for detailed information and how we can help alleviate operational risk and meet your compliance obligations