We now have an independent fintech firm bought out by much older, much larger firm. We’ve all seen this movie before, but the genre depends on your perspective.

Romance:  This is the one that is always promoted by the acquirer. Ron O’Hanley has already been on CNBC, warmly describing the synergies and rainbows that will naturally occur as a result of the deal. If you are a current user of CRIMS, you may be skeptical, but for those of you out there that that found a relationship with CRD senior management to be stressful, volatile and sometimes completely bewildering, you may have reason to feel optimistic about a bank. Bankers can be cool and distant, but at least they’re predictable.  

Action-Adventure:  Big banks have lots of money and lots of people, right? All of those new features you’ve been waiting for will now be fast-tracked. Upgrades will happen with a push of a button. Bugs will be a thing of the past, as they are annihilated by the new auto-immune system. The newest version even has an built-in translator, so when the credit derivative traders describe the same workflow six different ways, the views will auto-configure for their current and future needs.

Actually, that’s the sci-fi version, coming to you soon in zero gravity.

A better plan is to get clarity on the key things your firm needs (not the whole JIRA database), prepare a few slides that succinctly describe what is unique about your business to the new relationship managers and set a schedule for follow-up meetings before their calendars fill up. (And remember, they still can’t fix it if you can’t recreate it.)

Horror:  The hair on the back of your neck stands up as a chill fills the office. Strange whispers in the hallway, but when you look—no one is there. A muffled shriek from another cube makes you start from your chair, and your heart is pounding as the chat box materializes on your screen.  

No, please no!  Not the OMS!! 

Senior management wants a huddle meeting to discuss the possibility of a (gulp) conversion. Images of the last conversion rise, unbidden, in the dark recesses of your mind.  Shattered budgets, PMO departments broken by the 4,700 hundred rows of the project plan; colleagues crushed under the weight of the Power Point decks and bright-eyed business analysts’ enthusiasm consumed by voracious issues lists.   

Take a deep breath. Keep your wits about you and don’t agree to any timelines yet. Also, it’s really cold in the conference room, so grab a jacket. And remember--IMP can help. You may also email us directly at info@impconsults.com or call (617) 314-7415.

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]]>Compliance and RiskOMSInvestment TechnologyProject ManagementFront OfficeDavid DigginsTue, 19 Jun 2018 15:30:00 +0000https://www.impconsults.com/news/2018/6/19/mifid-ii-best-execution-podcast-part-4-how-one-of-your-peer-firms-addressed-the-challenge5674801ddf40f37eb35441f8:5697fe6e816924d794b306b2:5b22c28f575d1f168c43ea63In Part 3 of this podcast series we discovered why complying with MiFID II is so much more challenging then MiFID I and we offered some tips for firms struggling with MiFID's fixed income requirements. If you missed that episode, or any of the episodes in this series, use the links below to get caught up!

PART 1: Top 5 On and Off Venue Reporting Requirements
PART 2: Demonstrating Best Execution
PART 3: What Makes MiFID II So Challenging?

In this final episode of the series, Jon Gold asks Alex James about his experiences working on a MiFID II project for an IMP client. Listen to how one of your peer firms rose to MiFID II's challenges and succeeded.

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In the previous two episodes of this podcast series we talked about MiFID II's top 5 on and off venue reporting requirements and the need to demonstrate best execution across all asset classes for the reporting year. 

Missed an episode?
Listen to Part 1
Listen to Part 2

In Part 3 of this podcast, find out why MiFID II is so much more complex than MiFID 1, and what firms can do to comply on the fixed income front.

Be sure to listen to next week's final installment of this podcast series when Jon Gold talks to Alex James about the challenges he faces on his current MiFID data project.

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In PART 1 of this podcast series, we discussed the top 5 on and off venue reporting requirements of MiFID II. In this next episode we will delve into achieving the second requirement, that being the need to demonstrate best execution across all asset classes for the reporting year.

Listen to Episode 2 of our MiFID II podcast now!

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Listen to Episode 1 of our MiFID II podcast now!

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Best Execution, More than Just Best Price

Download The MiFID II Fixed Income Best Execution Checklist

Best execution rules are intended to protect investors by ensuring that investment firms seek the best possible result for their clients “taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.” These rules have been a component of MiFID, and are not new. However, MiFID II prompts a few major changes, and casts a wider net across significantly more asset classes, not just equities and equity-like instruments. Five of the biggest high-level changes include:

1. Increased obligation from “all reasonable steps” to “all sufficient steps”

2. Best execution to be considered for each class of financial instruments, including fixed income, FX and derivatives

3. Reporting required on the top 5 execution venues annually

4. Introduction of a new type of venue, the Organized Trading Facility (OTF)

5. Policy disclosures to be made on the firm's website, and updated annually

The upgrade from "reasonable" to "sufficient" conveys the regulators' view that best execution is focused on the consistency of overall execution quality over the reporting period, as opposed to achieving the best price for a given trade. Furthermore, it emphasizes the infrastructure needed to support and to measure these results, such as: best execution policies, data capture and retention, summary execution reporting, and periodic adjustments to improve these overall quality levels.

RTS 28 Disclosures on Policy and Top Five Venues

The Regulatory Technology Standards (RTS) developed by ESMA help to guide the specifics of best execution. RTS 28 specifically, is intended to enable the public and investors to evaluate the quality which results from a firm’s execution practices. Although MiFID II went into effect on January 3, 2018, the first RTS 28 disclosures had to be published on or before April 30th, 2018, and needed to detail previous best execution policies and include a summary of venues. At a high-level, RTS 28 includes:

1.)  An annual report stating the policy that the investment firm follows to execute client orders
2.)  Distinction between client orders executed directly on venues and those executed through brokers
3.)  Analysis on the top five execution venues for each class of financial instrument and the quality of execution obtained, including number and share of orders executed at each

The data component of RTS 28 can be the most burdensome to manage, depending on the size of the firm and the complexity of their investment strategies. In order to rank the top venues as required, data capture at the transaction/order level will be required. Different report formats apply to retail client orders versus professional. Although directed orders are included in these aggregates, they must be broken out and reported as a share of the overall totals.

In addition to the total executed metrics, the data must support reporting segregation according to security type, as defined in RTS 28, and by whether the order was active or passive. This is RTS 28 terminology describing whether the order decreased liquidity by lifting an offer or hitting a bid (active), or added to it by, for example, coming in between bid and offer (passive). Securities financing transactions are excluded but are reported separately under its own (more compact) report format. Orders for "eligible counterparties" (who do not provide investment advice) are exempt from the best execution rules.

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Best execution: what is best execution? Best Ex is the determination of how well a trader performed when buying or selling a security. Transactions include: price, timing, size or order, etc.

Regulators care about Best Ex because they want to be sure that money managers are doing a good job when they invest money for their clients. In fact, if your firm has an equity based business, you are probably using a tool or product that gives you a transaction cost analysis — or TCA report — which evaluates Best Ex.

Part of determining that money managers are doing a good job, is to make sure that traders pay competitive broker commissions to trade securities on behalf of their clients. Didn't traders already do that? Not necessarily.

Why else would they choose a broker?

Brokers can offer "soft dollars" to a trader of firm. Soft dollars are like credits firms can use to buy other services. Isn't that sort of like a kick-back? That's was how the regulators eventually viewed it. Many firms have phased out their soft-dollaring programs together.

New directives like MiFID II now require that money managers get permission from clients and set up special research payment accounts so clients understand, agree, and budget for research — or opt out.

As of April, 2018, EU regulators require that money managers be able to prove, on-demand, they have achieved best ex for their client. If money managers have been tracking this stuff for years to figure out traders performance, it shouldn't be that hard to do, right?

Yes, for most equities. Fixed income is a bit more complicated. To understand why, watch our fixed income execution video (coming soon!)

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Jane Stabile, IMP's President, interviews Matt Gould in this short (7 minute) podcast to discover how firms can prepare for a due diligence review, and how due diligence can ultimately improve a firms business.

For more on due diligence, read IMP's previous blog entry, Due Diligence: You'll Know It When You See It.

Back in the day, while I was still performing due diligence reviews as part of my job, I found that a lot of people in the industry thought that there was a magic formula for evaluating a subadvisor or fund. It was viewed as a bit of a secret, that perhaps nobody else knew. And yet, my work was actually more of a scientific exercise in performing basic research, mixed with the art of “knowing it when I see it.”

The following are 7 tips for your firm’s next due diligence review.

1)    Collect materials (ADV, DDQ from firm, Prop. Questionnaire, etc): Evaluate regulatory landscape, client/exposure/product, the Manager's general risks.

2)    Understand the overall business and where it operates: A due diligence officer’s first task is to get to know a company and understand its business. Is it a big firm with robust processes and resources, or a small shop with a shoestring budget? Does the firm deal with easily traded/settled securities, or are they trading term loans, derivative contracts, reinsurance, physical real estate, and/or private equity?

3)    Track the flow of money into and out of the firm – from investment to redemption: What are the inherent risks and how are they mitigated? Once a due diligence officer knows how a firm does business, the next step is to review the trading process from beginning to end.

4)    Talk to the traders: We know what they trade; now we need to know how they trade. What’s their approach to opening and closing positions? What technology do they use and how do they use it? How do they measure trading performance?

5)    Talk with Operations: How are trades captured and communicated to Ops? How do they confirm and settle? Evaluate the reconciliation process — what happens with fails? How are business continuity challenges handled? Review real examples.

6)    Talk to compliance and risk management about their overall program: Include past exams and the results, current annual assessment, and prior year over year changes. Be sure to assess how the compliance and risk program fits their business and the regulatory environment they operate in. Do they have the right level of resources?

7)    What is the IT infrastructure like: Evaluate the disaster recovery protocols. And business continuity. What steps are being taken to ensure cyber security and the safety of confidential data? Smaller firms used to be able to hide, but now everyone’s a target.

Onsite meetings are a critical part of a due diligence review and one where many clues to possible problems are discovered. If you've been in a lot of offices, you know what the business should look like and how it should be organized. You can recognize when something isn't right. For example:

• Is the compliance team located in a basement closet?
• Does Operations look like a sea of paper?
• Do people seem stressed?
• Can they articulate what they actually do vs. what the due diligence questionnaire says?

With experience, you know a firm that passes a review from one that doesn't. Take it from a former due diligence officer; you’ll know it when you see it.

IMP can provide your firm with help completing an operational or compliance process review. Furthermore, we offer solutions that ensure transparency, accountability, and adhesion to firm protocols regarding trading and compliance processes while also making sure your firm gets the most out of its technology solutions. Click here to learn more about our CLEAR compliance tools or ask a specialist for more information.

Investor Protection

Although all of MiFID II is in some way driven by the overarching goal of investor protection, there are certain changes to product and account classifications. Ensuring products are appropriate for the client is not new, but there are MiFID II specific articles that outline how you must carry out appropriateness tests. MiFID II also redefines "professional" (currently "Institutional") accounts, such that some such accounts may now need to be treated as retail accounts with accompanying changes to appropriate investment standards.

Best Execution

There are different requirements under MiFID II for best execution reporting, depending on if you are a broker-dealer / market maker vs. an investment manager. If you are an investment manager, the required annual best execution summary reports will require collecting a great deal of data so that execution quality can later be ranked by asset class, trading venue, retail vs. professional, and passive (adding liquidity to the market) vs. aggressive (taking liquidity from the market).

What this augurs are more formal best execution policies, because investment firms will now need to report on their execution quality relative to specific best execution standards for a true comparison.

Trading Transparency

The objective for trading transparency is to reduce the opaque parts of the market such as derivatives that are traded privately, and to reduce the use of dark pools. Under MiFID II, all trading venues, must publish current bid and offer prices and the depth of the trading interest on a continuous basis. For equity that means every minute and for fixed income that means every 15 minutes.

Post-trade Reporting

Post-trade reporting entails some of the heaviest lifting for an asset manager because it includes increased requirements for both the client reporting and transaction reporting. Reporting will be more thoroughly addressed in a follow up piece in IMP’s MiFID II Series.

Unbundling Research

One of the most talked about pieces of MiFID II is evaluating for and paying for research. EU investment firms as of the implementation of MiFID II, will no longer be able to accept any third party benefits, whether monetary or non-monetary. As a result, "soft dollars" may no longer be used to pay for research.

Investment firms must now explicitly separate these research charges out via devices such as a Research Payment Account (RPA), or pay for them themselves as a cost.  In addition to unbundling, MiFID II requires written policies that covers how published research will benefit clients.

From our perspective, these objectives overlap somewhat, particularly when it comes to where and how they impact the trade flow and reporting. For example, the degree to which broker research factors into an investment decision may need to be reflected in the cost / benefit justification of the research. 

IMP also covers the five areas of focus in the first video of our MiFID II video series. Please click here to view all four videos including the topics:  five areas of focus, impact on front office, implications for non-EU asset managers, and reporting vs. publish.

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MiFID II Next Steps
 
Visit IMP Consulting's MiFID II Preparation Resource Page for more information or contact Jane Stabile at jmstabile@impconsults.com with questions.

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MiFID II Alphabet Soup
MTF, OTF, RM, RPA, LEI….how can anyone keep track of the long list of MiFID II acronyms? Click here to download the MiFID II Acronym Cheat Sheet
 
Visit the MiFID II Preparation Resource Page for more information or contact Jon Gold at jgold@impconsults.com with questions.

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IMP heard you, loud and clear. As a result, we’re rolling out a slower, more detailed video series to help you to either prepare for the January 3rd deadline, or educate yourself on the basics of what this massive directive entails.

The first video covers an introduction, timeline, and reviews the five focus areas of MiFID II. Future short videos will cover topics including:

• Areas of business/systems impacted

• Trade publication vs. transaction reporting

• Programs & policies impacted

• Impact on order flows

Watch the first installment of our MiFID II video series: Will You Be MiFID II Compliant? Five Areas of Focus.

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However, don’t get too comfortable just yet. With refinements being released as recently as July, MiFID II seems to always have something new in store. Compliance professionals need to understand the changes taking place in the front, middle and back office as well as the potential impact to the systems that support them. To some firms, this has meant strengthening the role of the compliance officer in anticipation of increased regulatory scrutiny.

So take a minute to walk through (or around) three of the potential pitfalls for non-EU firms. Or take 45 minutes, and watch IMP’s webinar, hosted in conjunction with the National Society of Compliance Professionals (NSCP). Following are three areas where increased compliance scrutiny may be warranted:

Account Onboarding: Onboarding new accounts may introduce new asset classes and classifications.

This may sound intuitive. However, at IMP we work with clients who have acquired new funds or entirely new lines of business, often encompassing new asset classes. One of the cornerstones of MiFID II is its expansion from equities to most other asset classes, particularly debt and derivatives. Determinations including account suitability and reporting will increasingly be driven, in whole or in part by security attributes.

Trade Surveillance: Be prepared to collect and maintain considerably more data about each MiFID II transaction.

Speaking of reporting, a major expansion of data is required from investment firms regarding the entire trade life cycle. This ranges from the time an investment is decided upon, even if it’s by an algorithm, through ensuring best execution standards are met, and allocations are fairly and appropriately made in the event of partial fills. If you’re in surveillance, you’ll want to make sure that the policies on which you have signed off have actually been implemented and are being followed every day.

Fund Classification: Review EU accounts and verify that they are properly classified

Protection of EU investors is a hallmark of MiFID II. In most cases, a trade that affects such an investor will be subject to the scrutiny of EU regulators.  In some cases, what your firm considers professional accounts today can be reclassified as retail accounts under MiFID II in January 2018, which affects suitability and reporting requirements. A third classification under MiFID II is the Eligible Counterparty, which is specifically related to a firm’s status as a trade counterparty. Compliance teams will need to ensure each receives the appropriate protections applicable under MiFID II.

If you are unsure of next steps, contact IMP for guidance on how you can get started. You can also visit our MiFID II Preparation web page for general information on next steps.

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The Rise of MiFID II

First, let’s look at MiFID, or what we refer to as “MiFID I”. MiFID is the Markets in Financial Instruments Directive (2004/39/EC). It has been applicable across the European Union since November 2007. Its goal was to improve the competitiveness of EU financial markets by:

• Creating a single market for investment services and activities

• Ensuring a high degree of “harmonised protection” for investors in financial instruments

MiFID I covered:

• Conducts of business and organizational requirements for investment firms

• Authorization requirements for regulated markets

• Regulatory reporting, to avoid market abuse

• Trade transparency obligations for shares

• Rules on the admission of financial instruments to trading

The financial crisis of 2008-2009 proved MiFID insufficient in ensuring the hoped-for level playing field and transparent market, because it really covered mostly equity. As a response, in walked MiFID II and its associated regulations “MiFIR.” The legislative proposal for MiFID II was adopted on October 20, 2011 by the European Commission to revise MiFID I. Due to feedback from the industry and certain delays, the implementation was pushed into 2017. The MiFID II Directive is set to become law in Member States on July 3, 2017. All entities impacted by MiFID II will have to begin reporting, as required, as of January 3, 2018. If your firm has to report under any of the requirements of MiFID II, you’ll need to be equipped to do so by that date.

Does MiFID II Apply to You?

There is a misconception that if your firm is a US asset manager, then you don’t need to worry about MiFID II, when in reality you do. Even if your firm doesn’t have a physical presence in the EU, there may be components of the rule that are still applicable to what you’re doing.

For example, in looking at the chart below, if you have no physical presence in the EU but provide sub-advisory services to an EU-subject manager, you will still need to comply with MiFID II because the manager (your client) is subject to the regulation. Or, if you’re marketing cross-border products and services to Euro clients, you will still need to comply.

But wait, there is more, and it can get a bit tricky for those who thought they were safe within the confines of the US.

Even if there is no direct applicability to the US firm, and even if the US firm is trading for US clients, the trade details must still be published in near real time if they are trading on an EU trading venue. These include “Regulated Markets” (RM), “Multilateral Trading Facilities” (MTF), Organised Trading Facilities” (OTF) and “Systematic Internalisers” (SI). This is to support the MiFID II goal of price transparency and standards of best execution.

So does MiFID II apply to you? As they say in the UK, it’s bloody likely. 

Related Content: Preparing for MiFID II

* Our blog content is not intended to convey or constitute legal advice, and is not a substitute for obtaining legal advice from a qualified attorney. You should not act upon any such information without first seeking qualified professional counsel on your specific matter.

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So, you’re planning a project that has major consequences for your organization. It’s part of a larger initiative, so there are dependencies on its completion, and everyone is competing for budget and resources.

Perhaps one of the product vendors provided a “high-level” project plan on Excel. It has 1,800 rows.  You’ve spent some time integrating it into the overall project plan, but it is still only telling you part of what you need to know.

You have some good contacts in the organization, so you have a sense of who some of the most qualified people are, but you’ll be competing with other projects for their time and expertise. 

In the meantime, everyone is helpful, but they are all waiting on you:

• Your boss:  “I can get you the budget, just tell me what you need.”
• Your IT Peer:   “We can bring on additional help, but we need to first make sure we’re leveraging the resources we have.”
• HR: “Just give us detailed job descriptions, including skills, experience, etc., and we’ll get right on it.”
• Procurement:  “We will get you consulting resources, just get us the roles and experience you need, and keep it within the rate cards.”

(BTW, your spouse just texted you the great news that everyone can make it over to your house for the cookout this weekend, so you’ll need to do some shopping—what’s your ETA for tonight? —and your friends want to know what they can bring). 

There has to be a better way, right?

There is.  (There should be a small trumpet now, but we’ll settle for the wheeze of the K-cup coffee maker).

Imagine a visual map of exactly what the project needs—the kind of map where you could zoom in and zoom out, like Google Earth, to easily communicate what you need at a high level, and zoom in on the details to answer the specific questions.

What if you could create a similar map of current resources, their experience, skills and industry knowledge?

If you had that, you could compare what you have to what you need, and target the gaps in experience and knowledge with your precious budget so you don’t over spend or under-resource.

We call it Topography—a visual map that gives you more than north, south, east & west--it shows you the terrain, the virtual mountains (challenges) and valleys (pitfalls) of the project and how to assemble the kind of team that can tackle them. 

Check back soon, when we show you how we can visually explore a project’s needs and a project team’s shortcomings. With topography, project managers can rest assured that their teams have the knowledge and skills to get the project done right — the first time. 

Related Content: Heat-mapping Skill Sets for High Performance Teams

Bernard Madoff was well known for his “split strike conversion” strategies. Here, a complex option strategy obscured how the investments actually performed. The defendant, Kevin Amell, was alleged to have merely engaged in self-dealing, using trades which were most effectively executed to his advantage because of the structure of listed option markets.

In essence, it was alleged that Amell:

• Created personal brokerage accounts which were not disclosed nor trades reported to his employer;
  

• Failed to disclose his employment as a portfolio manager to the (personal account) brokers;
  

• Executed at least 265 sets of transactions in which the three legs below were sequenced:

1)     Placed personal buy limit orders for call options at a bid just above the national best bid (thus giving his orders first priority for a matching offer)

2)     Placed fund sell orders for these options at limit prices matching his (personal) bid price, which resulted in immediate fills, and

3)     Liquidated his newly acquired personal call options by selling at or near mid-market.

In this manner, the mid-market sale would earn approximately half the bid-offer spread. The two examples cited in the complaint had a total duration of under 10 minutes. While there were other versions of the transaction sequence, they all allegedly involved using the closed-end funds for which Arnell traded to provide liquidity at prices disadvantageous to the funds and advantageous to the hidden personal accounts.

Overall, it was claimed these transactions netted close to $2 million, for which Arnell’s funds will likely be liable to investors.

The trades described could have been executed using stocks, futures, or any asset with reasonable liquidity. The use of options, however, facilitates several attributes of these transactions.

• Exchange-listed options were used: Between the second and third legs, the position is long call options. Even having purchased them near the bottom of the bid-offer spread, this is still a risk position should AMZN move significantly. Conditions enabling a quick mid-market sale of these calls, thus earning the bid-to-mid spread, is a critical aspect of the scheme.
  

• The National Best Bid Offer (NBBO) option market spread convention ensures that the personal account (leg 1) buy order will be filled first when a matching (leg 2) offer is received. The aggressive seller closely following this bid was Arnell’s fund, thus allegedly channeling the benefit of the low sales prices to Arnell’s personal accounts.
  

• Options are liquid, but many are not too liquid: One of the 265 alleged schemes involved options on Amazon.com (AMZN). AMZN volume was 4.4 million shares on the day in question. Options on such a busy name trade frequently. However, there were 2,582 different options on AMZN that day, with widely varying levels of activity and bid-offer spread. This better permits selection of options with sufficiently wide spreads to make the transactions lucrative.
  

• Finally, with the enormous diversity of strike prices and expiration periods ranging from 2 to 842 days, it was easier to select an option contract whose price movement during the executions would be more muted, at least relative to underlying stock AMZN. This may be the sole component which relies on the characteristics of options themselves, rather than that of the market structure.

While all the price, volume and open interest data is available, stitching it together to create an effective preventative net would be difficult. There would certainly be valid reasons for the fund to take a position in call options on AMZN, so distinguishing self-dealing from legitimate activity is a challenge. Absent knowledge of the personal accounts obscures the self-dealing aspect as well. Therefore, this may have to be looked at as a case of best execution. 

Our highest priority is to satisfy the customer through early and continuous delivery of valuable software.

This idea certainly holds true for the vendor you are working with. Continuous delivery of high value software will only help you. However, from your project delivery standpoint, you must understand the true scope and testing requirements of releasing software updates and changes frequently. Can your team support that? When is a full regression test required? When is it not? Also, understand the true risk of the deliverables and how rigorous the system has been tested by the vendor – was it even tested?

Welcome changing requirements, even late in development. Agile processes harness change for the customer's competitive advantage.

This principle applies more towards the vendor producing the software. Most would find this principle hard to argue against if they want to remain competitive with the best of breed software solutions. However, it’s important to understand the criticality of the software you are implementing. For example, the implementation of a trading system is vital. You must always do a risk assessment on any requirements you submit to the vendor. Changing requirements at the last minutes usually has “delayed go-live” written all over it, and generally throws the risk meter over the scale.

Deliver working software frequently, from a couple of weeks to a couple of months, with a
preference to the shorter timescale.

It’s important that robust requirements are fully documented and vetted out early in any project. These releases are often formed in “sprints” in Agile, and a common mistake is to lose sight of the overall project plan and governing phases of the project. Even though your firm has decided to use Agile, you must make sure each sprint falls into place within the larger plan, makes sense, and has requirements documentation to support it.

Again, anyone would find it hard to argue that bug fixes and enhancements that are released sooner isn’t a great thing. The 2-3 week “Sprints” are most aligned with this principle, which forgoes robust requirements documentation. But, when you’re implementing a vendor product that is a critical system (such as an OM), it may not necessarily be the best approach where detailed requirements and traceability is an absolute must.

To access the full version of this blog with all 12 principles, click here.

Voting ends one week from today! Any one in the financial industry is eligible to be heard. Cast you ballot for IMP Consulting by visiting the FTF News Awards voting page and scrolling down to #6. What could be a better way to spend 5 minutes of a snowy Spring day at the end of March?

We’re really excited about the nomination, as a great deal of work has gone into developing this tool to help compliance teams manage regulatory risk. We thank you in advance for your support.  Learn more about CLEAR™ clicking this link.