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Defining Parallel and Similar Processes For Global Equity Reporting Purposes
Defining Parallel and Similar Processes For Global Equity Reporting Purposes
The Client was a global investment bank with a major UK trading operation. The client was expanding by acquisition and new clients trading in the emerging markets. The existing methodology used for the calculation of equity positions held relied on a heavily manual process and many aspects of international co-operation. This was coupled with a lack of systems infrastructure and manual completion of standardised forms.
A firm is required to report to the FSA when their trading of a stock crosses a threshold on purchase or disposal, including connected persons, person discharging managerial responsibility & directors.
The Panel on Takeovers and Mergers (the Panel) is an independent body, established in 1968, whose main functions are to issue and administer the City Code on Takeovers and Mergers (the Code) and to supervise and regulate takeovers and other matters to which the Code applies. Its central objective is to ensure fair treatment for all shareholders in takeover bids.
CEI Compliance were asked to provide a solution to support the project and provide a central point of contact as well as interface with the compliance and risk IT departments. Half-way through the project, after identifying the scalability, the scope was increased to accommodate worldwide equities for global reporting to enable the investment research team to provide accurate conflict of interest disclosures
The UK Regulator expected Disclosure and Transparency reports to be made at certain thresholds of positions taken or disposed of. The Panel for Takeovers and Mergers equally expected certain declarations to be made for impacted parties or related holdings, or the bank could have been in breach of the rules.
The solution was to install a Compliance Business Analyst within the project to work with the project manager and direct the developer on the process flow, exceptions and exceptions of the two reporting requirements as well as the on the project. The BA then grew the processes and translated them for the developer to design the system and user interface and provide automatic completion of the standardised forms for transmission by compliance after their approval on the go/ no go function and final amendment if trades had been altered post report running.
The Investment Research element required identification of trading entities, systems and holdings that would impact the reporting requirements other than UK or dual listed equities.
The roll out to the worldwide community was commenced after the parameters and specifications had been agreed, with the bank staff finalising the inputs.
The overall result was an extremely successful project that delivered on time and within budget against a revised plan. The client was able to switch on the new methodology and use this in the course of regular trading and risk management activities. The new methodology enabled the client to more accurately identify their trading positions as well as improve the capacity to provide reports to the interested parties with confidence and authority.
Total time spent 10 months. Resource Cost 264,000 Internal Cost approx. 350,000 Senior Management sleep value - priceless
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