Every rule, every transaction, every time.
X-COMPLY evaluates your complete rule book at each valuation and replays it for every transaction in between. Breaches are classified, given a deadline and followed until they are resolved.
- 32
- UCITS rules prepared, each named with its article
- 10
- ways to set a limit, from % of NAV to relative VaR
- 4
- netting stages in the commitment approach
- Every trade
- replayed against the whole rule book
Three questions a compliance officer asks
- Question Are we inside the limits right now?
Every rule is evaluated at each valuation and again after every transaction since the last one. Each result is passed, warning or breached – with the usage next to the limit.
- Question Did we cause this breach, or did the market?
X-COMPLY proposes active or passive from two counterfactual runs: old positions at new prices, new positions at old prices. The officer confirms.
- Question Which rule produced this result?
Every save creates a new rule version, and each result names the version that produced it.
A UCITS rule book that is already written.
The 32 mandatory rules of Directive 2009/65/EC come prepared, each named with its article and its counterpart in Liechtenstein law. A second set adds the national options. Assign a set to a fund and it is checked from the next valuation.
- Issuer limits: 5/40, 20 % per group, 35 % sovereign, OTC counterparty 10 % and 5 %
- Funds and unlisted assets: 20 % per target fund, 30 % other funds, 10 % unlisted
- Borrowing: 10 % temporary, 15 % in total
- Seven prohibitions, from uncovered short sales to precious metals
- Control limits: 10 % of voting rights, 25 % of a target fund
- Liechtenstein set: minimum fund assets and 25/80 for covered bonds
A set-up page per fund asks seven questions – regulation, domicile, exposure method, index tracking, sovereign exemption – and proposes the rule sets to assign.
A rule builder for everything the prospectus adds.
Mandates, internal guidelines and prospectus restrictions are built from the same blocks as the regulatory rules.
A rule can apply only where a fund field has a given value; otherwise the result is “not applicable”, with the reason stated.
- 01Selection
- Asset types, currencies and conditions on any field: issuer, counterparty, rating, dates, quantities. Nineteen derived fields are ready, from the issuer’s group to netting agreements.
- 02Grouping
- Per instrument or underlying, by any field – per issuer, group, counterparty or sector – or as one bucket for quotas.
- 03Measure
- Six measures: value, exposure, a field, value floored at zero, value netted under a netting agreement, or a count.
- 04Limit
- Ten comparisons: share of fund value, of gross exposure or of external assets, commitment, concentration with a soft and a hard threshold, absolute amounts, absolute and relative VaR.
- 05Warning and breach
- Each rule carries a breach value and an optional warning value. The editor rejects a warning that could never warn.
- 06Dry run
- An unsaved rule is evaluated against any valuation of the last two years. Nothing is stored until you save.
Derivative exposure, measured the way the regulator does.
Each derivative is converted into the exposure of its underlying and then netted. The fund chooses how its global exposure is measured: commitment, absolute VaR or relative VaR.
- Conversion
Ten conversion methods: futures, FX forwards with both legs, delta-weighted options, total return swaps, credit-linked notes, convertibles, rights and credit default swaps.
- Netting
Same asset, same currency pair, same underlying, then duration netting in four maturity bands. Of an FX hedge, only the over-hedge counts.
- Look-through
A rule can look through to a derivative’s underlying. Target funds that are valued in X-FOLIO are resolved into their positions, up to ten levels deep.
Credit default swaps, index and basket derivatives are deliberately never netted.
Breaches with a cause, a deadline and a history.
A breach is more than a red flag. X-COMPLY records the day it first occurred, proposes whether it is active or passive, and follows it until it is resolved.
- Five results: passed, warning, breached, not applicable, waiting
- Active or passive, proposed from two counterfactual runs
- Solve-by date: the same day for active, twenty days for passive
- A note per breach, printed in the reports with its author
- New, open and resolved breaches of all funds in one daily report
- Breaches and new warnings shown in the activity feed as they occur
Checked between valuations, not only at them.
After each valuation, every transaction since the previous one is replayed in order, and the complete rule book is evaluated after each. A breach that opened with one trade and closed with the next is on record.
- The complete rule book after every single transaction
- Prices from the last official close, or interpolated between valuations
- Drill-down from the moment to the rule, the group and the position
- Intraday breaches in their own section of the compliance report
- Pre-trade: the same rules run on draft orders before they are sent
Intraday checks are licensed as an option of their own. They see what transactions cause; a limit crossed by a price move alone shows at the next valuation.
Rules from the prospectus, proposed for review.
Upload the prospectus as a PDF or paste the text. X-FOLIO reads it section by section, finds the investment restrictions and says for each whether it can be expressed as a rule.
- Every restriction quoted and checked against the source text
- Four verdicts: not a portfolio rule, expressible, needs data, not expressible
- Proposals open in the rule editor, with a dry run before saving
- A rule from one sentence, typed or spoken
- ISINs, IBANs and fund or client names are held back before anything is sent
- Runs on the language model you choose, including one you host
The assistant never saves anything. A person reviews, tests and activates every rule.
Evidence, not only a status.
What the compliance officer, the board and the auditor receive from X-COMPLY.
- PDF report
Compliance report
Generated after every valuation in each report language of the fund, and delivered by e-mail or SFTP.
- Overview of all rules with limit, usage, utilisation bar and status
- UCITS rules in six groups: general, issuers, utilisation, borrowing, prohibitions, control limits
- One page per rule: reference value, limit, utilisation, status
- The positions behind each rule with quantity, price, value, exposure and share
- Breach notes next to the rule they belong to
- Intraday section, where that option is licensed
- PDF report
Breach tracking report
All funds over a date range – on a daily schedule or on demand, one file per language.
- Key figures and a cross table: new, open, resolved by active and passive
- Overview day by day
- Every breach with rule, current value, limit and excess
- Note with author, solve-by date and days left
- On screen
Rule results of a valuation
The working view of the compliance officer.
- Usage, limit and status per rule, with drill-down to groups and positions
- Active or passive, solve-by date and note, edited in place
- Commitment approach: totals and the positions netted at each stage
- Passed and breached rules at a glance, and the trend over valuation dates
- On screen
Comparison of two valuations
What changed in compliance between two dates.
- Rules newly breached, still breached and resolved
- Warnings that appeared and warnings that cleared
- Change in headroom per rule
- On screen
Alerts in the application
Pushed live, without a reload.
- Number of rule breaches of a finished valuation
- Rules that are newly in warning
- Valuations with a breach, a warning or an intraday finding in the valuation list
From assignment to report.
The same five steps at every valuation.
- 1 Assign
Rule sets and single rules are assigned to the fund, with validity dates.
- 2 Measure
The valuation computes exposure, commitment and – where chosen – VaR.
- 3 Evaluate
Every rule is checked. The result names the rule version.
- 4 Classify
Breaches are proposed as active or passive and receive a deadline.
- 5 Report
The compliance report is rendered and delivered; the breach report follows daily.
Methods, by name.
The terms your auditors use – and what stands behind each of them in the product.
Rule sets
- 32 UCITS rules (Directive 2009/65/EC)
- 2 rules UCITS Liechtenstein
- Your own sets per fund or mandate
- Assignment with valid-from and valid-to
- Rule names in nine locales for the reports
Rule builder
- Include lists for asset type and currency
- Conditions on fields, quantities, dates, numbers
- 19 derived fields
- 6 measures, 10 comparison types
- Breach and warning thresholds
- Dry run on past valuations
Exposure
- 10 conversion methods for derivatives
- Commitment approach in 4 netting stages
- Duration netting, switched on per fund
- Gross exposure and derivatives notional
- Global exposure by commitment or VaR
- Coverage of delivery obligations
Breach handling
- Passed, warning, breached, not applicable, waiting
- Active or passive with a proposal
- First-breached date per episode
- Solve-by date and note
- Daily breach report with catch-up
UCITS set-up
- Seven questions per fund
- Register of sovereign exemptions
- Required fields per asset type
- Daily completeness check of the data
Audit
- New rule version on every save
- Each result names its rule version
- Assignment changes are logged
- A changed rule marks valuations as stale
- Export of every table as CSV or XLSX
Not in the module today Breach notification by e-mail (today: in the application and by report), ready-made rule sets beyond UCITS, and a history view of rule versions.
