Regulatory Interpretation

7/31/2019 Regulatory Interpretation

1/20

Defining parallel and similar processes for global

equity reporting purposes


2/20

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.


3/20

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.


4/20

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.


5/20

CEI Compliance were asked to provide a solution

to support the project and provide a central pointof contact as well as interface with the

compliance and risk IT departments.

Half-way through the project, after identifying thescalability, the scope was increased to

accommodate worldwide equities for global

reporting to enable the investment

research team to provide accurateconflict of interest disclosures


6/20

The UK Regulator expected Disclosure and

Transparency reports to be made at certainthresholds of positions taken or disposed of.

The Panel for Takeovers and Mergers equally

expected certain declarations to be made forimpacted parties or related holdings, or the bank

could have been in breach of the rules.


7/20

The solution was to install a Compliance Business

Analyst within the project to work with theproject 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 andtranslated 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.


8/20

The Investment Research element required

identification of trading entities, systems andholdings 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.


9/20

The overall result was an extremely successful

project that delivered on time and within budgetagainst 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 thecapacity to provide reports to the

interested parties with confidence

and authority.


10/20

Total time spent 10 months.

Resource Cost 264,000 Internal Cost approx. 350,000

Senior Management sleep value - priceless


11/20

You are always dealing with the principalwhenyou are dealing with my firm. This means that I am the

relationship manager and there is no junior partner towhom responsibility will be transferred. There is nodecreased accountability, no "hand-off" to a less-informed colleague. If your interests are at stakecontinually, shouldnt you reasonably expect my

continual involvement? We can usually provide resources on a "just in

time" basis. That is, our projects do not have to coverexcessive overhead, such as multiple offices, largeadministrative backup, recruiting, partner perks, etc.

We are organized to efficiently provide everything thatyou, as the buyer needs, but nothing more than thatwhich means that you are paying for value and resultsand only minimum overhead.


12/20

There is more likelihood ofyour privacy

and confidentiality being observed withfewer people working on the project. We(and/or the few people we might also involve)are constant which means that there isnt the

need to sift through dozens of differing

perceptions. Were faster. We can respond to requests

quickly, and return all calls within four hourswhich means to you that there is no need to

worry about a bureaucracy, delays andunknown people on the other end of thephone


13/20

Since we handle fewer concurrent projects thanlarger firms, our attention is focused on the job at

hand. This means that you dont have to"compete" with another dozen or so of ourclients, which may be larger, paying more or aremore time-demanding. We structure our work sothatevery client receives maximum

attention. Your investment is controlled. There is no

"meter running". We work for a fixed, value-based, project fee. Large firms cant afford to dothat as readily because of all the people involved

and their own insistence on measuring theirsuccess by billable hours. We measure our successby client objectives reached, not in time units.


14/20

The expertise that larger firms use is often white-labelling for them by a pool of consultants

available in the marketplace at any one time. Weselect our consultants frompractisingsubject matter experts which means thatyou obtain the same or better expertise for less

money, because;

Inevitably, we are less expensive. Thereare economies to using someone who can basetheir fees on each situation and not on a pre-

determined service scale or need for reaching apractice quota. This means quite simply bettervalue to you.


15/20

We will conduct an initial appraisal at our cost only charging for expenses

We will make a proposal based on our

appraisal with your outcomes and needs

We will discuss the precise scope with youand provide you with a project price

We will complete the work to your original

scope and satisfaction

Phase 1

Phase 2

Phase 3

Click Mouse Reveal Next Phase

Phase 4


16/20

We have a wealth of Financial Services Experience, and due to

the remedial nature of our work forming over 60% of our

business and that is conducted under a Non Disclosure Regime,

we cannot demonstrate every client.


17/20

We Do have a large

amount of experience in a

number of other fields and

industries within the major

utilities and even LocalAuthorities.


18/20

We can provide all manner of assistance in

Initial risk assessment or audit an initial analysis toidentify higher risk areas of the business and weaknessesin procedures. We also do risk management design.

Business development business analysis advice oradvice on particular issues for example, how your firm isTreating Customers Fairly and an action plan for

implementing TCF across your business. Help with setting up procedures for example procedural

manuals for recruitment, training and competence,complaints handling and anti-money laundering. May alsoinclude templates for disclosure documents, fact-finds andregisters.

File audits checks to ensure that procedures are beingfollowed and identify good practices and weaknesses

Complaints Handling cost effective and project managedfrom start to finish making your response robust andconsistent


19/20

We can provide all manner of assistance in;

Technical support may include advice on particularproducts or regulatory reporting. May be available invarious formats, including website, helpdesk and individualtechnical advice.

Training for example competency assessments, trainingopportunities or product risk guidance. May be online

support, regulatory updates or seminar based. Support on individual issues for example in dealing with

a complaint, a financial promotion or a particular suitabilityletter.

Financial promotions (all areas of advertisement) - fullsupport which would include websites, brochures, DVD's,

email templates, client mail shots, adverts, contactingexisting clients and so on.

Remedial work helping to action remedial workrequired by the FSA.

And much more just ask!


20/20

CEI Compliance Limited

www.cei-compliance-limited.co.uk

Tel 0800 689 9 689 (UK)

Tel (+44) 7092 289901 (Int)

We operate across the UK, Europe

and the Middle East.

Currently exploring opportunities in

Latin America

Regulatory Interpretation

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