MiFID II: RTS 28 and Five of the Biggest Changes for Best Execution

MiFID II: RTS 28 and Five of the Biggest Changes for Best Execution

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

Understand Best Execution (In Less Than 2 Minutes)

Understand Best Execution (In Less Than 2 Minutes)

Best execution: what is best execution? Best Ex is the determination of how well a trader performed when buying or selling a security. Transactions include: price, timing, size or order, etc.

Regulators care about Best Ex because they want to be sure that money managers are doing a good job when they invest money for their clients. In fact, if your firm has an equity based business, you are probably using a tool or product that gives you a transaction cost analysis — or TCA report — which evaluates Best Ex.

Read More

Due Diligence: An Asset In Your Arsenal

Due Diligence: An Asset In Your Arsenal

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

MiFID II Across Five Areas of Focus

MiFID II Across Five Areas of Focus

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

Will You Be MiFID II Compliant? Publish, Report or Perish

Will You Be MiFID II Compliant? Publish, Report or Perish

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

Will You Be MifID II Compliant? Impact on Non-EU Asset Managers

Will You Be MifID II Compliant? Impact on Non-EU Asset Managers

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

Will You Be MiFID II Compliant? Five Areas of Focus

Will You Be MiFID II Compliant? Five Areas of Focus

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

MiFID Who? Three Immediate Areas Where Non-EU Compliance Teams Need to Pay Attention

MiFID Who? Three Immediate Areas Where Non-EU Compliance Teams Need to Pay Attention

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

Make the Best Compliance Solution CLEAR

Make the Best Compliance Solution CLEAR

Voting ends one week from today! Any one in the financial industry is eligible to be heard. Cast you ballot for IMP Consulting by visiting the FTF News Awards voting page and scrolling down to #6. What could be a better way to spend 5 minutes of a snowy Spring day at the end of March?

Read More

Trade Compliance Video Series – Cross-trading: What NOT to do

Trade Compliance Video Series – Cross-trading: What NOT to do

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.

Read More

Trade Compliance Video Series - See The Cause of Hundreds of Violations

Trade Compliance Video Series - See The Cause of Hundreds of Violations

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.

For more information on how your compliance team can update your trade OMS compliance rule library, contact Michael Toomey or visit www.impconsults.com/CLEAR.

Read More

Trade Compliance Video Series – Watch the First 2 Videos Now!

Trade Compliance Video Series – Watch the First 2 Videos Now!

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

Heat-mapping Skill Sets – Creating high-performance teams for investment management projects (Full Transcript)

Heat-mapping Skill Sets – Creating high-performance teams for investment management projects (Full Transcript)

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

Best of IMP’s Blog for 2016

Best of IMP’s Blog for 2016

If you made it to midnight on New Year’s Eve, you may have kicked off 2017 by asking (or singing) the traditional first question of the year, “Should auld acquaintance be forgot, and never brought to mind?”

That answer may be a resounding “yes” for most of 2016’s news, events, politics and even celebrity deaths (from David Bowie to Carrie Fisher) – but for IMP’s blog, we think that there are ten top posts worth remembering in the coming year.

In the countdown to the most popular, the top 10 posts of 2016 are as follows:

Read More

The “Plain English” Myth of Coding a Compliance Rule Library

Compliance Rule “Coding:” What does it really mean to “code” a compliance rule?  If you have a home-grown system, it may mean that it is written in a SQL-like fashion, and some programming skills are necessary.  If you have a commercial system, however, “coding” the rules is a bit of a misnomer. It is shorthand for the tasks involved in turning the “plain English” legal definitions in a prospectus, SAI, client agreement, indenture, or regulation, into a logical statement that can be processed by your compliance system. Most of the market-leading systems have a “plain English” interface that facilitates rule coding by non-programmers.

Why, then, is rule coding so challenging?

The issue is that the commercial interfaces, while helpful, do not alleviate the necessity of crafting precise, logical statements.  In fact, most of the logical thinking about how to translate a compliance mandate should take place before the rules are written. 

Read More

Top 5 Compliance Trends of 2016

Welcome to 2016. While resolutions are still fresh, IMP wanted to share five trends and regulatory changes to keep in mind in the new year. Our compliance experts monitor updates to SEC regulations and other compliance news in order to keep up to speed with regulatory pain points that our clients are facing, and help develop solutions to assist them. (Our blog also contains posts on the following topics).

Our top five for 2016:

Read More

The Best of IMP’s Blog in 2015

If you’ve been following IMP’s blog over the last year, you’ve seen our team of experts leverage their hands-on industry experience to share information and insight on relevant topics ranging from compliance to implementation to “managing” managed service providers. 

We’ve taken a look at the ten most popular blog posts of 2015 and provided our subscribers with the list below in case you missed one or you would like to read it one more time. If you’re new to IMP’s blog and wish to subscribe for 2016 please click to subscribe.

Read More

An Update to the 2016 Compliance Date Rule 2a7 Revisions

In 2014, the SEC announced the first significant changes to Rule 2a-7 since the comprehensive post-financial crisis revisions announced in 2010 (see our blog post from earlier this year, entitled “Preparing for the 2016 Rule 2a7 Requirements”). At that time, the SEC also announced that they were “re-proposing” the elimination of credit rating requirements, a change that would be in line with section 939A of the Dodd-Frank Act. This section called for amending rules that pertain to the reliance on ratings from credit rating agencies. Just this past September, the Commission announced that the removal of the language in Rule 2a-7 pertaining to the relied upon NRSRO* credit ratings would have a compliance date of October 14, 2016. This means the revision takes effect the same time as the majority of the changes that were announced in 2014. 

Read More

Shareholder Disclosure – Schedule 13D and 13G

As firms expand into new markets, the task of monitoring shareholder filing requirements has become increasingly demanding.

Investment managers and funds that have discretion over or beneficially own more than certain amounts of US equity securities registered under the US Securities Exchange Act of 1934 may have to report these holdings to the SEC.  All markets around the globe agree that shareholder disclosure requirements are good for the industry.  The problem is that each jurisdiction operates independently. Therefore this has led to an unlimited number of ways the requirements have been implemented.  Keeping up with the various regulations in different countries is challenging and onerous.  Timing of the filings may differ along with the thresholds. 

Read More

Compliance at a Glance: Rule Setup Errors

At IMP, we see every day examples of how uncontrolled library growth, inadequate scrutiny and inconsistent interpretations of client guidelines can cause errors and missed violations that risk monetary and reputational loss for CCOs and compliance teams. 

Without a rigorous, annual testing of the automated compliance rule library and supporting data, the results portfolio managers and compliance teams rely upon are statistically likely to harbor error rates of 25% or more. In fact, we find that between 25% and 40% of the coding backing these systems is, on average, incorrect - a fact that shocks compliance teams.

Read More