A look into the future: What may the SEC have in store for Rule 38a1?

As with all business decisions, there are pros and cons to implementing a major change to the way that your firm’s operations work. With today’s trend towards outsourcing to managed service providers in the front-office, such as OMS and compliance systems, the obvious upside is that asset managers are able to refocus their energies away from the day-to-day operation of their systems, with the downside being that transparency into systems is lost. With that being the case, if asset managers do not have a clear grasp of their provider’s process and controls, they risk losing money, clients, their reputation, and perhaps their company. Do you want to be in this press release in the future?

Read More

Q&A with Bryon Williston

Bryon Williston is featured in a TSAM Boston 2015 article, Q&A with Bryon Williston.  He discusses the growth and advantages of outsourced operating models.

IMP Consulting is a Knowledge Partner for the upcoming conference.  We look forward to sharing more insights with you there. 

Read More

CLEAR™: Three Tips for Naming Your Compliance Rules

Coding compliance rules in an automated system is a task that takes significant time and experience to master. In most cases, depending on the system you are using, you will need to learn an entire new vocabulary of coding terms.  Over my many years of working with compliance rule libraries, I’ve come to learn that more often than not, naming newly coded rules accurately is overlooked during the test setup process, yet it’s a critical part of managing a rules library properly.

One of the key goals of the rule naming process is to allow portfolio managers, traders, or compliance analysts to quickly recognize the guideline to which a rule name is referring. Based on its decade plus of experience in working on automated compliance systems, IMP has come across numerous situations where rule names set up by others were not effective, causing business users to spend valuable time and energy working to understand which compliance guideline was causing an exception.

In order to ensure that the names of your rules are clear, accurate and easy to understand, here are three tips to make the rule naming process a successful undertaking.

Read More

Compliance Automation – If the Gears are Grinding, “We Hear You”

Much like the sounds that our cars make as it steadily declines into a small fortune of repairs, trading compliance libraries also notify us when it’s on the verge of breaking down. Like cars, many people see their trading compliance library as a self-contained machine. As long as the car gets us to our final destination, or in this case, the compliance reports run on a daily basis and pre and post-trade compliance is runningthe system is working and the investment team can safely traverse the market without worrying about a trading problem. However, when we look under the hood, the compliance automation is actually an interaction between the automated rules, the data and trading. When those three key gears are properly moving together, we see a well-oiled machine. When one or more of the gears is grinding, we need to figure out what’s making that noise before we end up with an old jalopy that is destined to break down at the worst possible time.

Read More