Control Room Compliance

CRC helps clients build and assess their Control Rooms.

  • 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:

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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.

information-barriers

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.

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Training

Train employees on P&P’s on how to handle MNPI, avoid insider trading, information barriers and conflicts management.

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Policies and Procedures

Written P&P’s that describe processes for securing MNPI and preventing and detecting its misuse.

surveillance

Surveillance and Monitoring

Firms should monitor firm, customer and employee personal trading to investigate any possible misuse of MNPI.

standards

Need to Know” Standards

Establish a “need to know” standard culture to protect MNPI and confidential client information.

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System Access Controls

System access and electronic information barriers should be established to secure folders, files, databases and systems.

watch-list

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.

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Employee Personal Trading

Employee trading policies to monitor employee personal trading.

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Restricted List

The Restricted List is a confidential list of issuers whose securities are subject to restrictions on sales, trading or research activities.

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Conflict Management

Multi-service financial institutions must have a process to identify and manage conflicts of interest (e.g. – firm, customer and employee conflicts).

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.

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