Compliance monitoring
The compliance tests run on all trades and holdings rather than a sample. Each exception goes to a named person, with the evidence.
Checks
Each test runs on each trade and each holding in scope.
Suitability is measured on the whole portfolio against the client's risk rating, as well as on the individual trade.
The same approval rule applies however a product enters a portfolio: upload, trade, link or manual entry. Administrators cannot bypass it.
Staff trades are checked against client orders in the same security, including trades in the opposite direction.
A trade that needs approval waits until it has one. A complex product needs its explanation and risk warning on file.
The results of each test, rule by rule, on one page.
Each check names the SFC paragraph behind it, for example FMCC 3.9.1 for opposite trades.
The tests read only data that reconciliation has already matched to the bank. A test cannot pass on data that has not been checked.
What you receive
Exception list, each item with one owner
Senior Management Summary, by rule
History of each test run, for an SFC inspection
TAC runs the tests on each transaction.
Our compliance team investigates each exception and records the outcome.
Your principals review the summary and sign off the quarter.