FundConnect’s Pass-Through Service contains the unique ability for allowing any distributor to gain free access to your core data (EMT, KIID/KID) and includes absolutely no charges for you.

Receiving data from Third Party Service Providers adds an additional layer of complexity and data risk, which requires substantial hands-on relationship management and support from FundConnect.

- Often a Third Party Provider does not handle all set of data or all funds and we have to combine sources in fund universe management along with experiencing data inconsistency and missing coverage across different data types
- Data validation becomes more time consuming and extends the time of issue resolution
- Often third parties have their own template or delivery method which would require back-and-forth discussions from both sides

We are happy to deal with these issues but for obvious reasons, it cannot be part of a free industry service. The service requires from the Asset Manager a full commitment and responsibility for providing compliant and correctly updated data to the market in a self-sustainable manner. It should be addressed a direct delivery.

An agreement that outlines:
1. Who will be responsible for the different sets of data i.e. fund registry, corporate actions, and the different sets of data - Masterfile, EMT, EPT, NAV’s KIID/KIDs etc
2. Direct contact details to Asset Manager, in case of any upcoming issue, aside of agreed issues handling via the Third Party Service Provider
3. Commitment to make direct deliveries and error corrections in case the agreed data flow does not function in the intended manner, from a delivery and issue management perspective

A simple agreement stating:
1. The Service Provider will comply with the required delivery structures in the industry formats
2. The deliveries must be compliant with an STP process (Straight Through Processing)
3. Deliveries must be executed in a correct and timely manner eliminating any compliance risk
4. The Service Provider has to offer a service desk allowing FundConnect to comply with the SLA and compliance conditions agreed with the distributors
5. In the event that the Service Provider, also operates as a data collector, they must support an open exchange allowing FundConnect to deliver data to them in the industry formats as the golden source, similar to the role the Service Provider is performing for their clients
6. The Service Provider has to act in the sole interest of their client and must operate in a neutral manner, putting their own commercial interests aside and provide a complete and compliant set of data in a timely manner, in accordance with our delivery requirements

Please make sure to agree with your provider to send us information for all your products. As a Compliance Member, you can control which ISINs are public. It is important that requests for new ISINs from distributors can be handled as a simple activation process without unreasonable new data delivery exchange. All of your funds need to be setup in the system and ready for inclusion/activation. If not all ISINs are set up in the initial stage, continuous inclusion of new ISIN’s with the exception of new launches, might incur a setup charge.

In this case data deliveries to the distributors will become a bespoke service for the distributors and we will in each case ask the distributor to determine, if they wish us to perform a bespoke collection at their expense.

We will accept your EMT and documents deliveries as usual, but the data will only be updated in cases where the distributors enter a higher service level. FundConnect will make a commitment to monitor your data for updates and completeness. This also means that your instruments will not be available inside our portals, which are used by number of banks, distributors and brokers.

As more and more Fund Groups join the infrastructure, either as free Pass-Through Members or as Compliance Members, it will result in free data for the distributors. As a consequence, one shall expect that the distributors will limit the distribution of funds that are not committed to performing a compliant delivery which causes a challenging product governance process, combined with cost inefficiency and greater data quality risk.