Spending my days at IMP immersed in OMS conversions and upgrades, I have seen first-hand the repeated problems that arise from managing complex databases and the difficulty in accessing truly useful information from the mounds of OMS library data. Compliance projects continually present challenges that require agile thinking and adaptable solutions. Here’s 3 insider tips to ensure your compliance projects turn out successfully.
Insider Trading: Ensuring Your Team Acts in Good Faith
What it means for a corporate insider or company to act in “good faith” is about to dramatically change when it comes to insider trading.
Four Signs Your OMS Rule Library Urgently Needs a Review
As the 2023 fiscal year gets off to a running start, asset management firms face increasingly acute ramifications of risky data management practices. News sources continue to pump out weekly articles headlining immense fines and reputation hits due to compliance issues within some of the most well-known firms.
Overcoming the Compliance Stigma
Compliance professionals often get cast into the perpetual role of “bad guys” as they serve as primary, detail-centric rule enforcers on trades. As they shut down trade requests based on potential rule violations, they come under constant peer pressure to come up with exceptions or accommodations. They feel both the social and professional pressure to compromise, but they need to do so in a way that does not leaves their team feeling vulnerable to potential firm liability.
The Greenwashing of Investment Funds to Look ESG Compliant
The rising trend of ESG-focused investing has led to a large increase in funds being marketed as such. Upon closer inspection, however, many of these so called "ESG" funds prove not as friendly to the ESG cause as they claim. In recent years, a London-based climate change think tank, InfluenceMap, accused the majority of these funds of overstating their sustainability claims, a phenomenon known as "greenwashing." Even the former CIO for sustainable investing at BlackRock Inc., Tariq Fancy, stated that "sustainable investing boils down to little more than marketing hype, PR spin and disingenuous promises from the investment community (see here for more details).”
Open End Funds Liquidity Risk Management and Swing Prices – Hard Close
Pending amendments to Rule 22c-1 of the Investment Co. Act of 1940 (CFR Citation: 270.22c-1) would create a new hard close policy as the SEC plans to impose swing pricing. Getting to the heart of the proposed amendment means wading through complex documentation and given the potentially big impact of this proposed change I am diving in to help outline the upcoming changes.
Is "Cultural Fit" Over for 2023?
The National Society of Compliance Professionals (NSCP) recently offered a compelling webinar on the topic of “Allyship” which centers around personally helping marginalized colleagues move more center stage. By marginalized, the focus centers on those within the financial services industry who have historically been excluded from the conversation. The panelists came with thoughtful insights, including one panelist making this incredibly provocative statement: “Cultural fit is over!”
SEC Enforcement up 40% in Penalties YoY to $6.4 Billion
The SEC recently announced that they imposed a dramatic 40% increase in penalties from FY21 to FY22. This year's penalties mark highest in the last five years. Investment Advisors / Investment Companies faced 23% of the enforcement actions, the most of any Primary Classification. (https://www.sec.gov/files/fy22-enforcement-statistics.pdf )
Compliance Front and Center in Rising Interest Rate Environment
Jerome Powell and the Federal Reserve recently announced yet another 75-basis point rate hike, raising the central bank’s fed funds rate between 3.75% and 4%. Powell also signaled potential smaller rate hikes in the future, but that interest rates may ultimately rise higher than initially projected. This fourth consecutive 0.75-point increase by the Fed, shows their continued commitment to taming inflation and restoring price stability.
What's Driving RegTech?
As newlyweds of three months, my husband and I couldn't be happier. We each got to marry our best friend, we get to see each other all the time, and we are even expecting our first child. But over these last couple of months, we've also learned firsthand that marriage certainly comes with a need for adaptation. Before we married, I was queen of my castle in my own apartment. The bed was always made, the kitchen was always clean, and the clothes were always folded neatly. I quickly realized that household perfection was no longer a guarantee when there was someone else sharing space with me (especially when that someone is not too bothered by disorganization). I know some couples turn to outsourcing—sending out laundry and hiring cleaning services. Others turn to technology, investing in robotic vacuum cleaners and mops to keep the floors clean. I tried a more simple approach--I suggested some process improvements. Let's make a deal: how about the last person out of bed makes the bed? If I cook, will you clean up? If you can simply separate your laundry out for me, I'll take responsibility of the folding. So far these minor process changes have been working for us and I'm pleased to report that our townhouse is tidy.