Jane Stabile, IMP's President, interviews Matt Gould in this short (7 minute) podcast to discover how firms can prepare for a due diligence review, and how due diligence can ultimately improve a firms business.Read More
I know it when I see it. That’s what people say when they can’t describe what they instinctively see, or otherwise understand.
Back in the day, while I was still performing due diligence reviews as part of my job, I found that a lot of people in the industry thought that there was a magic formula for evaluating a subadvisor or fund. It was viewed as a bit of a secret, that perhaps nobody else knew. And yet, my work was actually more of a scientific exercise in performing basic research, mixed with the art of “knowing it when I see it.”
The following are 7 tips for your firm’s next due diligence review.Read More
Best execution rules are intended to protect investors by ensuring that investment firms seek the best possible result for their clients “taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.”
Best execution has been a component of MiFID, and not a new regulation to any firm – for the US or the European Union. However, MiFID II prompts a few major changes, and casts a wider net across significantly more asset classes, not just equities and equity-like instruments. Five of the biggest high-level changes include....Read More
The primary purpose of MiFID II is to enhance and strengthen “MiFID I.” However, MiFID II is a complicated, winding road of directives. The areas of business impacted cover everything from the investment decision, all the way to client reporting. The systems impacted span from the front to back office. To break the enormity of MiFID II for the sake of sanity, we will cover five main areas of focus.Read More
Retooling your Order Management System may be one requirement that you won’t be able to overlook if MiFID II applies to your firm.
From decision support, to trade execution, to reporting and the long-term retention of records – the impact on order flows spans the entire trade life cycle. In this short video, Jane Stabile walks through a basic fixed income flow and highlights just a few of the areas where MiFID II can create obstacles.
There has been a great deal of confusion over trade publication and transaction reporting, and there are several differences between the two. Read more to watch an overview of Trade Publication vs. Transaction Reporting presented by Jon Gold.Read More
There is a misconception that if your firm is a US asset manager, then you don’t need to worry about MiFID II, when in reality you do. Even if your firm doesn’t have a physical presence in the EU, there may be components of the rule that are still applicable to your client mix or your asset classes.Read More
Slow down! That was the number one request that IMP heard after our webinar, MiFID II: US Asset Managers Brace for Impact.
IMP heard you, loud and clear. As a result, we’re rolling out a slower, more detailed video series to help you to either prepare for the January 3rd deadline, or educate yourself on the basics of what this massive directive entails.Read More
If you’re in compliance, specifically with a Non-EU asset management firm, you may be prepared to sit back and enjoy the show that MiFID II has produced among those firms servicing clients in the European Union. It can be hard enough to keep up with the ever-changing landscape of regulations at home, never mind keep an eye on what goes on across the pond.
However, don’t get too comfortable just yet. With refinements being released as recently as July, MiFID II seems to always have something new in store. Compliance professionals need to understand the changes taking place in the front, middle and back office as well as the potential impact to the systems that support them. To some firms, this has meant strengthening the role of the compliance officer in anticipation of increased regulatory scrutiny.Read More
If you work for a US Investment Management firm, and are celebrating the notion that MiFID II won’t apply to you, it’s time to take off the party hats, and give this directive a second glance. MiFID II may just apply to you after all. This series, authored by IMP Consulting, will walk you through the highlights of the directive, and help to guide you in identifying how your firm may be impacted.*Read More
So, you’re planning a project that has major consequences for your organization. It’s part of a larger initiative, so there are dependencies on its completion, and everyone is competing for budget and resources.
Perhaps one of the product vendors provided a “high-level” project plan on Excel. It has 1,800 rows. You’ve spent some time integrating it into the overall project plan, but it is still only telling you part of what you need to know.Read More
Last week, it was reported that a portfolio manager for a major asset manager has agreed to plead guilty to defrauding investors in closed-end funds for which he executed option trades. One major newspaper described this as an “option scheme”. However, it may also be viewed as a scheme that was best effected by using options. There is a difference.
Bernard Madoff was well known for his “split strike conversion” strategies. Here, a complex option strategy obscured how the investments actually performed. Defendant Kevin Amell is alleged to have merely engaged in self-dealing, using trades which were most effectively executed to his advantage because of the structure of listed option markets.Read More
All methodologies work if you are dedicated. With Agile, the focus is often on its mechanical and operational components (daily stand-ups, sprints, etc.). What frequently falls short is the implementation of its greatest doctrines. Here, we’ve analyzed “Agile’s 12 Principles” to help you decide if the Agile Method is right for your project.Read More
When it comes to the Country of Risk, how can an American firm based in Florida cause a compliance alert for Canada? This strange alert makes no sense to the PM, but there is a common reason as to why it can happen.
In this week's edition of Trade Compliance from the Portfolio Manager’s Perspective, our PM, Jon Gold, shows how a disagreement between the modeling system and the compliance system causes an unexpected violation.
Cross-trading can be treacherous to navigate from a trade compliance perspective. It's no wonder that many firms don't allow it. You have to be very careful in the way that you set up an automated cross-trading rule, because a poorly coded rule can generate hundreds false violations, and cause the SEC to ask why your firm has so many overrides.
In this week's edition of Trade Compliance from the Portfolio Manager’s Perspective, our PM, Jon Gold, shows us what NOT to do when creating cross-trading rules.
This week, we’ll look at how one word caused hundreds of daily violations for a very frustrated PM, and walk through the simple fix that cut the risk of increased SEC scrutiny.Read More
Portfolio Managers and Traders frequently complain about the Automated Trading Compliance System. For Compliance teams, it’s as equally frustrating. When the rules were written, the PMs signed off on all of the rules for their funds. Why isn’t this working?
This video training series looks at real trade compliance experiences from the PM/Trader’s desk, and gives compliance teams a glimpse into why some rules aren’t working. It also discusses options for compliance teams to implement changes that will support a unified and seamless trading workflow.Read More
When it comes to OMS and Compliance systems upgrades, do firms typically have all of the right resources within their walls?
JS: Typically, no, because firms don’t do that every year. It’s something that they do every few years, so it’s unusual for them to have all the right staff on board at that time.
When these projects take off, how many of them involve initial analysis of the assigned team members, current skillsets as well as their ability and readiness to actually work on the project right now?
JS: It’s something that firms typically don’t do. Often times, they don’t know when they are going to get the budget. It can be somewhat fluid. The piece missing most is a dispassionate look at what they really need for the project. What often happens is that the firm will look around and see who is available and then just put those people on the project because they are available, rather than saying, “what does this project need,” and evaluating the people that they have on the team.Read More
Has this happened to you? Your firm decided to use the Agile methodology for the implementation of a vendor product, like your trade order management system (OMS). You’ve obviously heard of Agile before, and perhaps even worked on a team using it, yet you still find yourself engaged in the proverbial Google search to learn more about it. Your gut tells you it just doesn’t fit right with projects having little to do with development. In your search, you get lost with the numerous flavors of Agile from ones that use Post-It notes for requirements, to no written requirements at all. You ask yourself “If Agile is for development projects, why are we using this for an implementation?” Well, you are certainly not alone.
Why are more and more firms leveraging Agile you ask? The advantage of Agile lies in its twelve fundamental principles that were agreed upon at the turn of the century. While these principles are noble in their cause, the reality is, not all projects align perfectly with them. In addition, as the interpretation of Agile has expanded over the years, many of these core principles have lost their punch with the day-to-day mechanical operations of running an Agile team taking priority.Read More