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
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
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
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
When a process has been around for a long time, its familiarity makes it comfortable. Even if it is cumbersome, it is often tough to change, because the old process just feels and looks right. That presents a challenge, since nearly all of our projects have a stated goal of improving the business processes.Read More
There was a famous business book in the ‘80s called the “10-minute manager.” The book focused on how managers could be effective by better focusing their time and zeroing in on key issues. It then morphed to the “1-minute Manager,” probably to sell more books, but the point was the same.Read More
Two weeks ago I illustrated the often-strained relationship between Portfolio Managers (PMs) and the compliance team. PMs complain that the compliance team is slowing them down, whereas compliance professionals push back when PMs demand that compliance ‘fix it’. To combat tension, periodic communication between the PMs and compliance is needed. Understanding the PMs viewpoint on the current state of pre-trade compliance and mutual education as needed will facilitate a better working relationship.
In this article, I will offer some practical pointers to help improve and maintain the relationship between PMs and compliance. IMP Consulting’s experience working with multiple clients shows that a little proactivity from the compliance side calms things down, and allows an environment of trust to develop between the PM and compliance teams. Please note an underlying assumption is that the PMs have undergone proper system training. If this is not true, then training the PMs so they can properly understand and work with compliance alerts is critical and must be done first. Here are seven ways Compliance can foster a better working environment with PMs:Read More
An interesting dynamic exists between the Compliance team and Portfolio Managers at many investment management firms. Portfolio Managers complain that the Compliance team is slowing them down, whereas Compliance professionals fret when Portfolio Managers demand that Compliance ‘fix it’. With few exceptions, there is tension between Portfolio Managers and Compliance.
But why exactly does this tension exist? Of course there is a balancing act between efficiency and compliance, but there is more to it. To understand better, let’s first go over how orders are created, and importantly what the Portfolio Manager’s perspective is.
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
Since the Whistleblower Rules (Section 21F of the Securities Exchange Act of 1934) went into effect on August 12, 2011, the Securities and Exchange Commission (“SEC”) has awarded 15 whistleblowers. Payouts have totaled nearly $50 million out of an investor protection fund established by Congress in Section 922 of the Dodd-Frank Act.Read More
In a series of interviews with thought leaders on Tech & Ops Strategy in the Investment Management industry, the team at Osney Buy-Side & TSAM sat down with IMP's President, Jane Stabile.
Osney Buy-Side: Tell me a bit about your role at IMP Consulting.
As the President and founder of IMP Consulting, my role is to work with our team to constantly investigate and improve on our best practices. Working with dozens of asset management firms of all types over the years has enabled me to gain a broad industry perspective. IMP stands for “Implementation Management Professionals;” when I started the firm 10 years ago, I spent most of my time helping asset management firms with OMS implementations that had gone off track. Seeing the same patterns emerge at multiple firms led us to create an implementation “toolkit” that made it easier and faster to implement OMS and compliance. Read more on TSAM's website.
I’ll admit it, I am addicted to HGTV. In particular, I love the shows about renovation. You can buzz in and out of the room folding laundry or unloading groceries, and just really be in front of the TV for the “big reveal,” which is when the renovation is done and the homeowners get to see the results. My favorite show, “Love it or List It” has homeowners choosing to stay in their homes, post-renovation (“love it”) or sell their homes (“list it”) for something better that they have found.
No contingency: The homeowners typically have an older home, and they set a firm budget for the renovation, which they cannot possibly go beyond. The designer then begins the plan, with glowing descriptions of how she will achieve everything on the owners’ “must have” list, and stay within the budget.Read More
I have been sailing most of my life, and I religiously follow the blogs for several races throughout the year. The Newport Bermuda race, held bi-annually since 1936, is a one of my favorites. It is a grueling 635 nautical mile course that tests every aspect of a captain and crew--their planning, skills, discipline, and ability to handle unexpected challenges as a cohesive team.Read More