A key element of Securities and Exchange Commission ("SEC") Rule 204A-1 or the "Code of Ethics Rule", relates to personal securities trading by requiring all access persons of a registered investment adviser ("RIA") firm to submit securities holdings and transaction reports to the firm's Chief Compliance Officer ("CCO") or other designated person(s).
To simplify the submission and approval process of transaction reports, the MyRIACompliance® Employee Trade Monitoring solution automatically records, monitors, and consolidates employee personal securities transactions. The cloud-based software eliminates the need to request and review paper brokerage statements by allowing the advisory firm's CCO to automatically monitor employee transactions and holdings for both remote and in-office work forces. In this post, we will highlight the recent enhancements to our Employee Trade Monitoring solution.
Recent personal securities trade monitoring enhancements include the following new features:
Mass Upload via CSV file – Users can now download our CSV template(s) into Excel to upload their data, such as client transactions and restricted securities list within minutes.
Users can take advantage of this new upload feature for the following two separate key activities:
- Automatically identify front-running violations. Users can upload all client transactions into our Employee Trade Monitoring solution to automatically compare with employee transactions. Prior to this enhancement, only users who subscribed to both the Employee Trade Monitoring solution feature of MyRIACompliance®and Orion could benefit from the auto flag feature that identifies potential front-running trade violations. Now, all our employee trade monitoring users can say goodbye to manually cross-referencing spreadsheets by using the CSV upload feature for their client transactions.
- Seamlessly manage and update private restricted securities list in one quick upload. For firms who currently maintain a restricted securities list, this feature eliminates the time-consuming process of manually adding and removing restricted securities.
Clear Trade Function: This new feature makes it easier for supervisors to identify potential trade violations and streamlines the documentation of how any issues were resolved into the user’s compliance log. With a user-friendly interface, supervisors can seamlessly view executed trades and “clear” them out of the review list.
Pre-Clearance Automation Rule(s): Supervisory users can save time by setting customized parameters for the automated approval of employee’s personal trading requests. For example, the supervisor can select the maximum value and number of shares per personal trade request to be automatically pushed through the approval process. The firm's restricted list will still limit all trade requests.
Dynamic Ticker Database: The Dynamic Ticker database updates daily to support all actively listed stocks and ETFs on major US exchanges. This feature improves the system's ability to identify potential trading violations.
One of our company's longstanding commitments is to invest time and resources to make the MyRIACompliance® platform the industry leading compliance technology offering for RIA firms. Our in-house developers and product team are committed to continuously researching, enhancing, and creating new products and features to meet the evolving compliance challenges that investment advisers face.