How Disclosure Monitoring re-reads sources, versions them, classifies each change for materiality and gates removals on evidence.
Disclosure Monitoring treats a change as a difference between two versions it actually held. It re-reads each tracked source on a cadence, keeps every version with its hash, and classifies each difference so you only get paged for what matters. This page explains each step and the rules it holds itself to.
Re-read. Every tracked source is fetched again on a schedule. Register, sanctions, named-party and collateral monitors run on their own cadence.
Normalize and hash. The text is normalized before it is hashed with SHA-256, so a re-rendered page or reflowed PDF stays one version.
Compare. Only text that was actually read on both sides becomes a change. A different value, a removed statement or two sources that disagree is a change. Reflowed layout or a renamed heading is not.
Classify. Each change is classified for materiality.
Confirm. A confirmed change is notified. A draft waits and doesn’t count until it is confirmed.
The first time a source is read, the value is recorded as the first reading (1). Here the reserve_custodian field reads BNY Mellon.
One field, one source, four re-reads. The values are illustrative.
2
Editorial re-read
In March the PDF is re-rendered. The value is the same, so the change is Editorial · reflowed PDF (2) and is folded away.
3
Clarification
In May the document names The Bank of New York Mellon. It is the same party with a better name, so the change is a Clarification · same party (3). It stays on the timeline without paging anyone.
4
Material change
In August the custodian becomes State Street Bank. A new custodian is Material (4). It is the event a compliance desk sees first, with before, after and the quote.
5
Know the rules
A field that vanishes is re-read several times before it counts as removed (1). Monitoring doesn’t alert on every byte that moves, doesn’t pick a winner when two sources disagree and doesn’t treat a failed fetch as a withdrawn disclosure (2).
The rules Disclosure Monitoring holds itself to, and what it won't do.
Why didn't I get notified when the issuer reformatted its PDF?
Text is normalized before it is hashed, so a reflowed PDF stays one version. If the wording changed but the meaning didn’t, the change is Editorial and folded away.
What happens when two sources disagree?
Monitoring records both values and flags the disagreement. It doesn’t pick a winner.
Can a disclosure disappear because a website was down?
No. A failed fetch is never treated as a withdrawn disclosure, and a removal needs several re-reads first.