Use casesFinancial institutions & fintech

  • Portfolio management company

Fund limit and prospectus compliance

Every fund carries its own limits from the communiqué, its fund rules, and its prospectus; each morning every position must be checked, and every amendment must reach the rule table on its effective date.

With the systemEvery fund checked each morning by your rule table, each amendment read clause by clause; internal control decides.

Who decides
Internal control officer

KAP · 4 November 2026Illustrative

Prospectus amendment text · equity fund · new wording

Investment strategy: in addition to shares traded in Türkiye, the fund may invest in shares of foreign companies traded on foreign exchanges, within the limits in the asset table.

→ add a foreign-equity limit · applies from the KAP date

The document as it arrives. In red, what the system marks for your expert.

1. The work

Today

  1. ReadWhen a prospectus or the fund rules are amended, or SPK changes a communiqué, internal control reads the new text, works out which limits change for which fund, and updates the limit spreadsheet by hand.
  2. CheckEach morning, after the funds are valued, positions are checked against the single-issuer, group, deposit, and fund-type limits, partly in the fund accounting system and partly in spreadsheets.
  3. GatherFor every breach or near-limit position, someone pulls the trades and corporate actions to see whether a trade caused it or a price move did, and how many days are left to restore it.
  4. DecideThe internal control officer decides what each breach needs and reports it as your procedure writes; any trade to restore a limit is the portfolio manager's.

With the system

  1. ReadThe SLM reads the amended prospectus, fund rules, or communiqué clause by clause and lists what changes for each fund, with the rule-table change it calls for and its effective date, for internal control to approve.SLM
  2. CheckYour approved rule table, run as code, not a model, checks every position of every fund each morning against the communiqué, the fund rules, the prospectus, and your board's limits.Your rule
  3. GatherThe agent, with read-only access, builds one file per breach: the trades and corporate actions behind it, whether it is active or passive, the days left to restore it, and the manager's earlier notes.Agentic AI
  4. DecideThe internal control officer decides, as before; the portfolio manager decides any trade, and nothing changes in the rule table until a person approves it.Person decides

What lands on the desk

Internal control gets every fund already checked by its own rule table, each breach with its trades, its cause, and its window already gathered, and the amendment already read clause by clause. The new limit waits for a person's approval.

FIG. 1 · Exceptions fileIllustrative
Morning check · one umbrella fund family · 04.11.2026One passive breach, one fund near a limit, one amendment

Rule table · morning run

  • flaggedSingle-issuer limit, variable fundIII-52.1 art. 17/1-apassive breach after a price rise
  • Deposits at one bank, money-market fundart. 17/5near the limit
  • metGroup limit, debt-securities fundwithin

Agent · the breach file, read-only

  1. 1No trade in the issuer since the last check: a price move onlytrade log
  2. 2The thirty-day restore window opened todayart. 24/5
  3. 3The manager's earlier note on the position attached

SLM · amended prospectus, what changes

  • The equity fund may now hold foreign sharesprospectus, investment strategy

    • Add a foreign-equity limitChange

  • Effective date set by the KAP announcementannouncement

    • The new rule applies from that dateReview

  • New wording on the fund's risk profileprospectus, risks

    • No limit covers itGap
  • SLM
  • Agent
  • Code

Why a person decidesApproving a rule change is internal control's; any trade to restore a limit is the portfolio manager's.

DecidesInternal control officer

2. The system

For your technical team — skip it if you like.

How it works

In

  • New or amended prospectuses and fund rules
  • SPK communiqués and announcements
  • Your current rule table

  1. SLM · understands

    Prospectus and rule reader

    Fine-tuned on prospectuses, fund rules, and SPK texts

    Reads

    • Everything under In

    Out

    • Each limit with its clause
    • What changes, fund by fund
    • Rule-table changes, for approval
    • Effective date of each change

  2. Code · calculates

    Limit rule table

    The communiqué, prospectus, and board limits, run as code

    Reads

    • Each fund's positions and prices
    • The approved rule table

    Out

    • Each limit's use, fund by fund
    • Breaches and near-limit positions
    • Issuer, group, and deposit limits

  3. Agent · prepares

    Exceptions-file agent

    Fixed workflow, read-only

    Reads

    • The rule results
    • The day's trades and corporate actions

    Out

    • Active or passive, from the trade log
    • Days left to restore a passive breach
    • Trades and prices attached
    • The manager's earlier notes

  4. Decision

    Internal control officer

    Reads

    • The exceptions file and the proposed changes

    Out

    • Approves each rule-table change before it applies
    • Asks the portfolio manager to restore a limit
    • Reports as your procedure writes
    • The manager decides any trade
How the agent's work is arrangedFixed workflow

Fixed workflow

Every breach takes the same steps in the same order (pull the trades and corporate actions, set the restore window, attach the notes), so a fixed workflow fits and leaves the agent nothing to choose.

How the models are trained and tested

Your expert writes the test first. A step the test does not need is skipped, and we say why.

Show the training steps

Small language model (SLM)

  1. Test set

    200–400 past prospectus, fund-rule, and communiqué changes that your internal control and legal team already turned into rule-table changes, graded clause by clause.

  2. Dataset

    Your funds' prospectuses and fund rules over the years, their KAP announcements, and the rule-table changes that followed; no investor data.

  3. Continued pre-training (CPT)If needed

    Only if the base model fails the test on SPK and prospectus vocabulary.

  4. Supervised fine-tuning (SFT)

    On prospectus and fund-rule clauses mapped to the rule-table entries they produced.

  5. Reinforcement learning (RL)Skipped

    Skipped: a person approves every proposed rule against its clause, so no further reward is needed.

  6. Retrieval

    Retrieval supplies the current prospectuses, fund rules, and communiqués; the morning check runs on the approved rule table, never on the model.

Where the agentic system stops

The internal control officer approves every rule-table change before it applies and decides what each breach needs: a request to the portfolio manager, a report as your procedure writes, or, where restoring in time is impossible, a request to SPK for more time.

Show its tools, limits, and record
Tools and access
Reads fund accounting, the order and trade log, prices, and corporate actions; runs the approved rule table; read-only; writes only the exceptions file.
May not
Place, change, or cancel an order, change the rule table, approve a prospectus change, publish on KAP, contact SPK, the custodian, or an investor, suggest what to buy or sell, or grant itself any access.
Who decides and the written limit
Internal control officerThe internal control officer approves every rule-table change before it applies and decides what each breach needs: a request to the portfolio manager, a report as your procedure writes, or, where restoring in time is impossible, a request to SPK for more time. Any trade is the portfolio manager's, inside the fund's rules. The system never places or suggests a trade, never changes the approved rule table, never publishes on KAP, and never contacts SPK, the custodian, or an investor.
Stops when
An active breach, a passive breach near the end of its window, a limit the rule table cannot compute, a position without a price, or a prospectus change with no matching rule: the file goes to internal control, marked.
Record
The positions and prices used, the rule-table version, each result, the trades attached, and who approved, asked for, or reported what; kept as your procedure writes.

How agentic systems stay inside limits

3. Value and conditions

Where the time goes, and what your institution will measure.

Where the value comes from

  1. Every limit of every fund checked each morning, the same way.
  2. Amendments in the rule table on their effective date.
  3. Internal control hours moved from spreadsheets to the breaches.

What your institution measures

  • Breaches found the same day
  • Rule-table changes live on their effective date
  • Passive breaches restored within the window
  • Exceptions found later in an audit or inspection

Measured in the Decision Blueprint

Today's time from an amendment to its rule, the breaches found late, and the hours the morning check takes, from your internal control records, set the baseline; your institution sets the target.

Conditions

The rules, the data, and the known error, with its guard.

  • A fund's portfolio limits are written rules: one issuer, issuers held above a threshold together, one group, one issuer's debt in circulation, and deposits at one bank (SPK Communiqué III-52.1 art. 17/1-a to 17/1-ç and 17/5), with each fund type's minimums (art. 6); a free fund follows the limits on its KAP page instead (art. 25/1). A limit broken by price moves, dividends, or rights is restored within thirty days, which SPK may extend (art. 24/5). No machine-learning model is needed: the rule table runs them.
  • A prospectus change that may affect investors' decisions is approved by SPK, announced on KAP the working day after the permission arrives, and takes effect no sooner than ten working days later; other changes are made by the founder, announced on KAP, and reported to SPK together after each year end (art. 13/2). A free fund's change is announced at least thirty days before it takes effect (art. 25/8).
  • The portfolio management company's internal control checks that every portfolio's limits comply with the law, the fund rules, the prospectus, and the contract (SPK Communiqué III-55.1 art. 11/1-f); its risk management unit, independent of portfolio management, watches the board's risk limits daily and reports a breach to its manager the same day (art. 12/3, 12/4-c).
  • Fund assets are managed by portfolio managers with at least five years in the capital markets (III-52.1 art. 5/2), whose investment decisions rest on reliable reasons, information, and analyses (III-55.1 art. 33/1-f). The system checks and gathers; it never trades and never tells the manager what to buy or sell.

Start here

We take your funds' prospectuses and fund rules and a quarter of morning checks with internal control, rebuild the rule table from the texts, and test the reader on your own past amendments before anything is built.

Who builds it Every engagement is led by an engineer who has built machine-learning models that real decisions run on since 2012, and language models and agentic systems in production since 2024. About eqlx

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https://eqlx.ai/use-cases/fund-limit-compliance · Printed copy; the website is the current version.