Governing laws and regulatory authorities in most jurisdictions around the world require some form of disclosure or notification of ownership in equity and equity related securities of firms that are incorporated, or have their shares registered, traded or transacted in those jurisdictions.

Measures undertaken in a proactive manner position the firm favorably with regulators and other control authorities. Regulatory authorities expect owners of shares to be active in their disclosure obligations. As such, firms that own or hold shares for their clients in the securities of subject companies are required to accurately and timely disclose their ownership as defined in governing laws and by regulatory authorities. Accurate identification and sourcing of data representing reportable securities positions are paramount in fulfilling shares ownership, custody, management and discretionary reporting obligations, along with monitoring for compliance with trade restrictions.

Failure to accurately aggregate and disclose ownership in securities have resulted in liability and effective, proportionate and dissuasive sanctions against many financial institutions that failed to disclose or submitted late or inaccurate ownership or change in ownership filings in reportable securities held as required by governing laws and regulatory authorities. A reporting person is ultimately responsible for timely filing and could be held liable by regulatory agenciesfor failure