For disaggregation (i.e., aggregation exemptions), we allow our clients to set logic between entities in their corporate tree when they have either confirmed that the facts of their firm satisfy the disaggregation criteria in a given jurisdiction or a compliance regime (i.e., rule) within a jurisdiction. For most clients, this entails obtaining confirmation from their internal legal or compliance departments or directly securing documented disaggregation agreements with a regulator.

Some shareholding disclosure regimes might require (or allow) a signed agreement with the regulator, while for others, holding assurances regarding certain facts related to their corporate tree might suffice. This varies by jurisdiction. If a client is interested in disaggregation, we ask that they thoroughly review the aosphere memo section in each jurisdiction (usually in a section entitled "Exemptions from the aggregation principle" or similar) where they seek this and consult with their legal or compliance group on the matter. In the UK, for example, see sections A.2.6 and more saliently A.5.10.

We cannot advise on whether a client might disaggregate certain parts of their corporate tree for purposes of shareholding disclosure, but allows the functionality to do so if our clients have confirmed that their analysis aligns with the disaggregation rules of a given regime/jurisdiction.

If you would like to set up disaggregation, please contact your CSM, who will walk you through approving it in your environment and uploading the CSV file.

Your CSM will help sense-check the backing for disaggregation and request a CSV file containing the disaggregation from you.