Table of Contents
NICSA- D.M.R.
Technology & Compliance Report
Introduction and Executive
Summary
I. Survey
Participants
a. Investment Firms Represented
b. Total Assets under Management
c.
Product distribution channels
d. Participant job
titles
e. Organization
of the compliance function
II. Transfer
Agent Functions
a. Primary transfer
agents
b. Shareholder accounts
c. In-house systems
d. Customizable role-based
security
e. Breakpoint alerts
f. Changing loads
if discrepancies are found
g. Notification
of defined large trades
h. Display of sales
charge information on confirmations and statements
i. Market timing
monitoring
j.
Technology budget
k. Expectations
of service providers
l. Audit requirements
III. Rule 22 C-2
a. Responsibility
for intermediary agreements
b. Executing agreements
– some or all?
c. Number of agreements
d. Data elements
requested from intermediaries
e. Concerns
about agreements with intermediaries
i. Monitoring
divergent trading patterns
ii.
Identifying intermediaries
iii.
Executing and managing agreements
iv. Importing, controlling, and managing data
v.
Cost of required agreements
vi. Supporting multiple data feed formats
f. Multiple data feed formats – industry standard
g. Multiple data
feed formats – who will lead development?
h. Frequency of data
feeds
i. Monitoring data
from intermediaries
j. Storage of data
from intermediaries
k. Where third party
data will be stored
l. Complying
through automation
i.
Matching multiple shareholder purchase
ii. Capturing
TINs
iii.
Linking across recordkeeping systems
iv. Importing,
controlling and managing data
v. Monitoring
omnibus accounts
vi. Producing
reports for senior management and the Board
vii.
Need for flexible business rules
m. Managing data
flow
n. Chief
concerns
i. Internally
developed solutions
ii. Externally
developed solutions
iii.
Browser based solutions
iv. Integration
with in house systems
v. Auditability
of results
vi.
Flexible business rules
o. Results of
implementing new technology
i.
Reduction of manual processes
ii. Reduction
of staff expenses
iii.
Reduction of duplicative efforts
iv. Reduction
of business risk
v. Ability
to access information faster
vi.
Ability to streamline processes
vii.
More efficient operation
viii.
Auditability of results
p. Data received
from intermediaries
IV. Information
Security Planning
a. Chief
Information Security Officer
b. Information
Security budget trends
c. Use of third
party vendors
d. Third party
vendors – liability arrangements
e. Response to
regulated privacy and data security requirements
f. Security
measures taken
g. Security
risks
h. Storage of
personal or confidential data
i. Sensitive
data protection controls
j. Services used
k. Supported
encryption methods
V. Email
Compliance Practices
a. Volume of
email
b. Practices for screening and reviewing
c. Email retention
d. Regulatory
examination experience
All contents © 2005-2006, Diversified Management Resources, Inc. Please do not reproduce
or distribute without permission.
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