Filing Health Check
We take last year's Annex IV return for one of your funds, rebuild it from your own files and show you every place the two don't agree.
Each difference comes with the line in the filed XML and the sheet and cell in your files, so your team can check it in a couple of minutes.
We also run the return through the checks a regulator runs on its own, like the regional split adding up to 100% and every LEI being valid, and set out what the FCA's FRAME proposals would change for that fund.
From you we need last year's return for one fund, the files it was built from and two half-hour calls, one to start and one to go through the results. It usually takes about two weeks.
The files can be Excel workbooks or CSV exports. We don't read figures from PDFs or scans, and we never ask for passwords: send files through your own secure transfer link.
Not ready to share your records? Start with the return on its own. We check the filed XML against the regulator's format and rules, the check digits and the totals. That finds what can be seen from the return alone, and we'll tell you what it can't see. See a sample free check.
It's free for the first few firms. It isn't legal advice, and you still sign and file the return.
Request a Health Check
How the check works
- We open each fileYour filed return, in ESMA's format or the FCA's RegData format, and every workbook or CSV you send.If a file can't be read, we say exactly what it is (a PDF, a scan, an email, a password-protected file) and what to send instead. We never guess figures from it.
- We find the figures in your filesNAV, AuM, currency, period, regions, borrowing, the professional and retail split, turnover and the controlled companies, by reading the headings, wherever your administrator put them. If two files disagree, we say so and use neither.
- We rebuild the returnEach field is worked out from your files with fixed, written rules. The same files always give the same result.
- We compare, field by fieldEach field either matches, differs, or couldn't be checked from your files. Nothing is left out of the count.
- We check the return on its ownThe rules a regulator applies: the format, required fields, check digits, totals adding up to 100%, the euro rate.
- You get the reportEvery difference shows the line in the XML and the sheet and cell in your files. A person goes through it with you before anything is changed.
Here's what your check could look like
This is a real run of our check on a made-up fund. We built its return in the official format and slipped in eight mistakes, the kind that creep in when a return is put together by hand. Seven come back as differences. The eighth, a euro rate written the other way round from the records, comes back as a question, because the FCA's own guidance points both ways on that. Click any line to see what's wrong and how to fix it.
The return overstated NAV by £250,000, missed one controlled company and listed one the fund doesn't control. It also asks which way round the euro rate is written.
◆AuM and NAV overstated by £250,000 £412,850,000lines 49 and 53£412,600,000Fund Summary!B9
What's wrong. £250,000 more than your records. That is exactly the value in Valuation!C3 (Kestrel Holdings Ltd / Shareholder loan notes), so it was most likely added in by mistake.
Fix. Report £412,600,000 in both fields.
◆Europe (non-UK) share of NAV is wrong 25%line 11731.5%Fund Summary!B17
What's wrong. Your records put 31.5% of NAV in Europe (non-UK).
Fix. Report 31.5%.
◆Halden Robotics Ltd is missing Not listed72% owned, BuyoutPortfolio!A6
What's wrong. A 72% holding gives the fund control, so it belongs in the list of controlled companies.
Fix. Add it: LEI 5493ZYPTELRL50TQWD83, 72.00% voting rights, transaction type BOUT.
◆Brightwater Foods Ltd listed as controlled 35.00% of votesline 33535% heldPortfolio!D5
What's wrong. At 35%, control isn't presumed. It belongs in the list only if the fund controls the company another way, such as board rights.
Fix. Remove it, or keep it and record why the fund has control.
Show 3 more
◆Corvid Logistics Ltd: wrong LEI 54938BN2Q4ATL3XTKP42line 31654938BN2Q4TAL3XTKP42Portfolio!B3
What's wrong. In the filed LEI, characters 11 and 12 are swapped. It fails the check digits every LEI carries, so it can't be a real identifier.
Fix. Use the LEI for Corvid Logistics Ltd from your records after checking it on the GLEIF register.
◆Kestrel Holdings Ltd: voting rights 60%line 31165%Portfolio!D2
What's wrong. The return should show the fund's share of the votes. Your records show 65% (ownership; your files have no separate voting column).
Fix. Report 65.00%, unless the voting share differs from the ownership share.
◆Ardent Healthcare Group Ltd: deal type BOUT (buyout)line 326GCAP (growth capital)Portfolio!C4
What's wrong. Your records describe this deal as growth capital (GCAP). Buyout (BOUT) was filed.
Fix. Report GCAP.
Checks on the filed return
- ■Regional split of NAV adds up to 100% (an FCA validation rule)Adds up to 93.5%.
- ■Every LEI passes its check digitsCorvid Logistics Ltd (54938BN2Q4ATL3XTKP42)
- ●GBP to EUR rate is plausible0.8562 is plausible as GBP per one EUR, not as EUR per one GBP (1.05-1.3). The FCA's own guidance points both ways: its Q&A (Q3) says report the base currency to one EUR, while its validation guide multiplies the base-currency AuM by the rate to get euros. We've asked the FCA which it means. Confirm which convention you file in.
- ●Controlled companies hold over 50% of votesBrightwater Foods Ltd 35.00%. Fine only if control comes from other rights.
- ✓Valid against the FCA's Annex IV XML schema (v2, RegData)Valid.
- ✓No region below 0% or above 100% of NAVAll within 0-100%.
- ✓AuM is at least NAVAuM 412,850,000, NAV 412,850,000.
- ✓Every ISIN passes its check digitAll 2 pass.
- ✓No controlled company is listed twiceNone listed twice.
- ✓Fields ESMA requires are there, and none it forbidsAll present where required, none where forbidden.
- ✓Any 'other' deal type is describedNone used.
- ✓Liquidity, financing and investor splits add up to 100%Liquidity, financing and investor breakdowns all add up.
- ✓Clear of the common validation errors the FCA listsChecked principal exposures, portfolio concentrations, borrowing, re-hypothecation, preferential treatment: none of the errors on the list.
Every difference has a source
One real difference from our sample run on a made-up fund, followed from the report to the line in the return and the cell in the files.
£412,850,000lines 49 and 53£412,600,000Fund Summary!B9