Registrations expire quietly.
The passport notification is a one-off with a short statutory clock, and it rarely goes wrong. What goes wrong is the recurring calendar behind it — the annual regulator fee in a market you registered in four years ago, the tax reporting cycle, the data template that changed version, the KID that quietly went out of date.
The engine behind this module is written and exercised. What is not built is the enterprise half — assignment, approvals, execution and the audit trail — and it is being built with a small number of firms rather than for an imagined one.
ActionDesk is where the engineering and the selling go today. This is real, and it is next.
Ask about the betaThe risk lives between the events.
A registration agent files. Nobody holds the obligations that outlive the filing, which is why a lapse is usually discovered by somebody outside the firm.
Nobody owns the recurring calendar
A range in twelve markets is a few hundred recurring obligations, and no single person holds all of them. They are held instead by a spreadsheet, an inbox, and the fact that nothing has gone wrong yet.
Ten working days is not ten days
Ten working days in Frankfurt and ten in Milan are different ten days, and the difference is the market’s own public holidays. A clock that counts calendar days is wrong in every market that matters.
A red badge is not a consequence
Knowing something is late tells you nothing about what it costs. De-notification under Article 93a means an exit offer held open for thirty working days; for an AIF the same decision bars pre-marketing for thirty-six months.
Fees go stale by design
Regulator fee schedules are republished annually and sometimes mid-year. Any system that presents them without saying how they were sourced and when is quietly making things up.
The rule base is compiled, not typed.
Sixteen jurisdictions and five regimes held as structured rules — legal basis, clock length, who starts it, what stops it — read off the primary sources rather than transcribed from a vendor’s summary.
- Sixteen markets, field by field
- The legal basis each registration runs on, the clock that basis starts, the language its KID has to be in, what the regulator publishes about its fee, and the two markets where the settlement plumbing produces a local entity even though Article 92 forbids requiring one.
- Working-day clocks
- Statutory periods, annual fees, tax reporting cycles and template versions all count down against the calendar of the market that owns them, public holidays included.
- A critical-path planner
- Pick a date you want to be selling and the plan runs backwards — translation, documents, the notification file, then the statutory period the regulator owns. The leg you cannot compress is named rather than implied.
- Confidence on every fee
- Read from a primary source, taken from a secondary guide, or modelled — and the date it was read. A fee figure without that is a number somebody will quote to a regulator.
The same spine, pointed at a registration.
Nothing here is a separate system. These are the Consentra steps this module leans on hardest — the same code ActionDesk runs against SEC filings.
- 01
Source documents and data
Primary filings, custodian notices, agent messages and registry files — fetched, rate-limited, and archived exactly as served so everything above can be re-run.
- 02
Normalise the event or obligation
Six documents become one object with an identity, a kind, terms, conditions and a chain. A later document adopts the object an earlier one opened rather than starting a second copy of the truth.
- 04
Determine deadlines and rules
The date that binds, and the rule that set it — an offer expiry, a broker cut-off two days earlier, a record date, a statutory period counted in the working days of the market that owns it.
- 05
Assign the required actions
An event is not a notification. It is a set of things somebody has to do, each with an owner, a due date and a consequence if it slips.
- 08
Collect the evidence
What was sent, to whom, under which rule, on which date, with the document. Assembled as a by-product of the work rather than afterwards from memory.
What this is not, yet.
A beta that lists no limits is not a beta, it is a brochure.
- The rule base needs maintaining, not just building
- ESMA collects national marketing requirements periodically; individual regulators change them in between. Residual requirements are the most volatile field, and keeping them current is an ongoing job rather than a one-time import.
- Filing is not automated
- The module holds the obligation, the clock and the consequence, and produces the artefact. Submitting it to each regulator’s own portal is per-market plumbing that has not been built.
- Translation is a judgement call
- Whether a particular document must be translated is occasionally interpretation rather than rule. Where that is true the product says so rather than picking one and sounding certain.
Interested early is the useful kind.
Design partners shape what gets built first. If this is your problem, that conversation is more valuable to both of us than a waiting list.