Asset Atrium Compliance Framework
Internal Use Only
Active vs. passive breaches
An active breach results from a deliberate trade (for example, PM overrides a soft limit). A passive breach results from external events — market price movements, credit rating downgrades, corporate actions, or investor redemptions changing portfolio weights without any trade.

Post-trade compliance triggers

TriggerDescriptionFrequency
Scheduled daily runFull compliance re-check of all fund positions after NAV calculationDaily (post-NAV batch)
Trade settlementCompliance re-evaluated when T+n settlement updates positionsEvent-driven
Corporate action processingStock splits, mergers, spin-offs may change issuer concentrationsEvent-driven
Price movementSignificant intraday price moves can shift asset allocation weightsEvent-driven (threshold-based)
Credit rating changeMoody's/S&P/Fitch downgrade may breach credit quality floorsEvent-driven (data feed)
Investor redemptionLarge redemptions change portfolio weights without tradingEvent-driven
Benchmark rebalanceBenchmark index changes can affect relative-to-benchmark limitsQuarterly / ad-hoc

Passive breach detection

Passive breaches are detected during the scheduled daily compliance run. Asset Atrium compares current portfolio exposures (post-NAV) against all active mandate rules. Breaches caused by market movements or external events are classified as passive and subject to different remediation timelines than active breaches.

Remediation timelines

Breach OriginSeverityRemediation DeadlineEscalation
Active (PM trade)HardBlocked at pre-trade — no remediation neededN/A
Active (PM override)Soft5 business days to return within limitsCCO at day 3
Passive (market move)Soft10 business days to return within limitsCCO at day 7
Passive (credit downgrade)Hard30 days (regulatory grace period where applicable)CCO + board at day 15
Passive (corporate action)VariesNext rebalance window or 10 business daysPM + compliance review

Daily compliance report

After each scheduled post-trade compliance run, Asset Atrium generates a Daily Compliance Status Report containing:

UCITS passive breach rules
Under UCITS regulations, passive breaches of the 5/10/40 issuer concentration rule must be reported to the fund's management company within 1 business day. If the breach is not remedied within a reasonable timeframe, regulators (for example, CSSF for Luxembourg funds) must be notified. Asset Atrium automatically flags UCITS-specific breach reporting obligations.

Integration with breach manager

All post-trade breaches are automatically forwarded to the Breach Management module for lifecycle tracking. The breach record includes the triggering event, affected rule, current vs. limit values, and recommended remediation action.

Optimizing post-trade runs
For large fund families (500+ funds), post-trade compliance can be partitioned by processing zone. APAC funds are checked immediately after APAC NAV batch; EMEA and Americas follow their respective NAV windows. This prevents compliance bottlenecks during the global EOD cycle.