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 (the UK regulator at

the time) 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

• You are always dealing with the principal when you are dealing with my firm. This means that I am the relationship manager and there is no junior partner to whom responsibility will be transferred. There is no decreased accountability, no "hand-off" to a less-informed colleague. If your interests are at stake continually, shouldn’t 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 cover excessive overhead, such as multiple offices, large administrative backup, recruiting, partner perks, etc. We are organized to efficiently provide everything that you, as the buyer needs, but nothing more than that which means that you are paying for value and results and only minimum overhead.

• There is more likelihood of your privacy and confidentiality being observed with fewer people working on the project. We (and/or the few people we might also involve) are constant which means that there isn’t the need to sift through dozens of differing perceptions.

• We’re faster. We can respond to requests quickly, and return all calls within four hours which means to you that there is no need to worry about a bureaucracy, delays and unknown people on the other end of the phone

• Since we handle fewer concurrent projects than larger firms, our attention is focused on the job at hand. This means that you don’t have to "compete" with another dozen or so of our clients, which may be larger, paying more or are more time-demanding. We structure our work so that every client receives maximum attention.

• Your investment is controlled. There is no "meter running". We work for a fixed, value-based, project fee. Large firms can’t afford to do that as readily because of all the people involved and their own insistence on measuring their success by billable hours. We measure our success by client objectives reached, not in “time units”.

• 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. We

select our consultants from practising subject matter experts which means that you obtain the same or better expertise for less money, because;

• Inevitably, we are less expensive. There are economies to using someone who can base their fees on each situation and not on a pre-determined service scale or need for reaching a practice quota. This means quite simply better value to you.

We will conduct an initial appraisal at our cost – only charging for expenses (UK only)

We will make a proposal based on our appraisal with your outcomes and needs

We will discuss the precise scope with you

and provide you with a project price

We will complete the work to your original scope and satisfaction

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Phase 4

We have a wealth of Financial Services Experience, and due to the remedial and sensitive nature of our work forming over 60% of our business and that is conducted under a Non Disclosure Regime, we cannot demonstrate every client.

We Do have a large amount of experience in a number of other fields and industries within the major utilities and even Local Authorities.

We can provide all manner of assistance in• Initial risk assessment or audit — an initial analysis to

identify higher risk areas of the business and weaknesses in procedures. We also do risk management design.

• Business development — business analysis advice or advice on particular issues — for example, how your firm is Treating Customers Fairly and an action plan for implementing Conduct Risk across your business.

• Help with setting up procedures — for example procedural manuals for recruitment, training and competence, complaints handling and anti-money laundering. May also include templates for disclosure documents, fact-finds and registers.

• File audits — checks to ensure that procedures are being followed and identify good practices and weaknesses

• Complaints Handling – cost effective and project managed from start to finish making your response robust and consistent

• Technical support — may include advice on particular products or regulatory reporting. May be available in various formats, including website, helpdesk and individual technical advice.

• Training — for example competency assessments, training opportunities 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 suitability letter.

• Financial promotions (all areas of advertisement) -full support which would include websites, brochures, DVD's, email templates, client mail shots, adverts, contacting existing clients and so on.

• Remedial work — helping to action remedial work required by the FCA/PRA.

• And much more … just ask!

Compliance Consultant

www.complianceconsultant.org

Tel 07801 864980(UK)

Tel +44 7092 289901 (Int)

We operate across the UK, Europe and the Middle East.

Currently exploring opportunities in Latin America