Some investment managers use umbrella structures for various reasons, and these structures can also affect shareholding disclosure. We have created functionality around umbrella funds within the aggregation framework. This article explains the logic behind these umbrellas and their effect on the results generated when the rules are executed.

The article Aggregation Framework describes the general set-up in regards to aggregation level and structure. The umbrellas relate only to the aggregation level.

The article further defines all the various levels which the rules engine uses; these are:

Umbrella disclosures will trigger under rules which run on 'Portfolio' or 'AllEntitiesAndPortfolio'*. The logic we have implemented can be summarised in this way:

"If a portfolio's direct parent is an umbrella and if a portfolio level disclosure is required, the system will trigger the disclosure on the parent umbrella, aggregating all portfolios underneath that specific umbrella"

Below is a small example illustrating how this works. As mentioned, only rules with the aggregation levels 'Portfolio' or 'AllEntitiesAndPortfolio' will trigger these types of disclosures, so the below will display these two types of aggregation levels when an umbrella is part of the aggregation structure.

When your results trigger portfolio-level disclosures in cases where an umbrella exists, portfolios that have an umbrella as a direct parent (in the example, any portfolios under the EFP Dynamic Allocation Fund) will be aggregated under the umbrella, and a disclosure will be made on the umbrella level. As the EFP Discretionary Mandate does not have an umbrella parent, your results will trigger a disclosure on the portfolio itself, based solely on its assets.

Regarding the umbrella-level disclosures, this scenario is identical, and the logic the system uses is identical. The only difference is that your results will also trigger disclosures on the FA Capital Partners level, aggregating across all three portfolios.

Note: If an Umbrella does not have a Parent Entity, it will be considered a Top-Level Entity and, therefore, will trigger results under any rules that run on the Aggregate Level: Top-Level Entity.