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
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
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
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
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
Implementations and conversions present many challenges in the form of unexpected gaps, regulatory or business changes that must be accommodated, and complex problems that can tax the skills of your team. In our previous article, we took a look at the overall pitfalls for implementation. In this article, we’ll take a closer look at the top six pitfalls from a compliance perspective.Read More
Every year, the rescue workers of the White Mountains have to fetch hikers who started out their climb on a bright and sunny day in their shorts and tee shirts, with minimal supplies and little or no experience with the terrain. It was happening so often, that the New Hampshire Fish & Game Agency launched the “hikeSafe” program that has checklists for required gear, discussions of weather, technology recommendations, etc. Hikers who ignore the recommendations may find themselves with a bill from the Agency, for the tens of thousands of dollars expended during the search and rescue.
Technology professionals, under pressure to deliver on project deliverables, often bypass the tedium of inventorying the current state of systems, interfaces and data quality in favor of getting an immediate start on the project. They spend little time questioning the end users on the current terrain–which can be rife with disagreements about the goals of the project and competing needs–and fail to account for the changeable “weather” of regulatory requirements. Advocating for the time and budget to do a thorough current state analysis can be tough, but skipping it can often leave a project in need of an expensive rescue.Read More
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
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
On December 15, we blogged about the struggles that some high yield funds were having trouble with honoring redemption requests. One of them, the Third Avenue Focused Credit Fund, in lieu of cash, had taken steps to provide its shareholders with interests in a trust that would be used to liquidate the fund’s assets once it had been closed down. Since that time, the Fund has come to an agreement with the SEC, permitting it to postpone honoring redemption requests until it can liquidate the fund’s assets in orderly fashion.Read More
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
Unfortunately, despite the best intentions at the starting line, not every outsourcing project crosses the finish line as a success. IMP and TSAM asked survey respondents what they would do differently if they could do it over again. Not surprisingly, most responses had one key theme in common: firms would conduct a more thorough requirements analysis of their own needs; in conjunction with conducting a more in-depth validation of the vendor’s capabilities, including the vendor’s resources and qualifications.
Most notably, 50% of respondents said that they would conduct a Proof-of-Concept (POC) before signing the contract.Read More
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
If your firm is evaluating a build vs. buy decision regarding compliance software, you may find yourself facing many of the same decisions that you’d face when deciding on whether or not to buy or build a new home. Here are five keys things to consider when making that decision.Read More
Over its life span of more than 30 years, Rule 2a-7 has gone through no fewer than 5 updates. In 2010 we saw the most drastic changes to the rule since 1997 as a result of the Reserve Fund’s “breaking of the buck” in 2008 (due to the Lehman Brothers default). In July 2014, after several years of debate and discussion, the most recent changes to the rule, which will come into effect in October 2016, were announced.
The new rule will have greatest impact on Institutional Prime money market funds: however, government, and municipal money market funds (MMF) will also need to make specific changes in how they operate. All MMF will need to decide whether and how to utilize new tools provided to them by the law in order to prevent future runs on their assets by shareholders.Read More
Five years ago, on July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act was passed. As we look back, we see the changes the financial markets have undergone as well as those that have yet to be implemented. Not all of the changes are attributed to Dodd-Frank, however; there are a plethora of rules that everyone in the industry must now follow.
Commissioner Daniel M. Gallagher of the SEC put together a sampling of some of the rules that have come into effect since July of 2010. This particular chart was the impetus for this blog article. The chart includes rules from many organizations including the SEC, CFTC, OCC, FDIC, OFR, FinCEN and many others. In fact, it doesn’t even include state regulations or FINRA guidelines (See: Rules Applicable to U.S. Financial Services Holding Companies Since July 2010). Of course, this only represents the names of the rules, not the actual size of the documents behind them.Read More