CRC helps clients build and assess their Control Rooms and information barriers.
If your firm has access to material, nonpublic information (“MNPI”) and offers trading, sales, research and banking services, you have an obligation to have adequate policies, procedures and controls in place to prevent and detect the misuse of MNPI and address conflicts.
We assist clients in conducting Control Room framework assessments in the handling of MNPI and provide recommendations for developing, designing and implementation.
Framework Considerations:
Information Barriers
Physical and electronic information barriers to restrict and manage the flow of MNPI between employees who regularly acquire or develop such information, employees who buy, sell, or recommend securities and employees that do not have a need to know MNPI.
Training
Train employees on P&P’s on how to handle MNPI, avoid insider trading, information barriers, and conflict management.
Policies and Procedures
Written P&P’s that describe processes for securing MNPI and preventing and detecting its misuse.
Surveillance and Monitoring
Firms should monitor firm, customer and employee personal trading to investigate any possible misuse of MNPI.
Policies and Procedures
Written P&P’s that describe processes for securing MNPI and preventing and detecting its misuse.
Need to Know” Standards
Establish a “need to know” standard culture to protect MNPI and confidential client information.
System Access Controls
System access and electronic information barriers should be established to secure folders, files, databases and systems.
Watch List
The Watch List is a confidential list of issuers or securities about which the firm may have received MNPI or is reasonably likely to be engaged on an investment banking transaction.
Employee Personal Trading
The Watch List is a confidential list of issuers or securities about which the firm may have received MNPI or is reasonably likely to be engaged on an investment banking transaction.
Restricted List
The Restricted List is a confidential list of issuers whose securities are subject to restrictions on sales, trading or research activities.
Conflict Management
Multi-service financial institutions must have a process to identify and manage conflicts of interest (e.g. – firm, customer and employee conflicts).
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What We Do
At Compliance Risk Concepts, we provide clients with the critical skills and expertise required to establish, maintain and enhance a balanced and effective compliance operational risk management program. Contact us for more information on how we can provide financial consulting services for your organization.