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Effective Intermediary Governance
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Effective Intermediary Governance

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NICSA Intermediary Discussion Forum

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    Effective Intermediary Governance Effective Intermediary Governance Presentation Transcript

    • EFFECTIVE INTERMEDIARYGOVERNANCEEVOLVING BEST PRACTICESNICSA Intermediary DiscussionForumSeptember 2012
    • EFFECTIVE INTERMEDIARYGOVERNANCEOverview• Mutual fund transfer agency operations have changed significantly in recent years as a result of the widespread adoption of omnibus accounts.• Best practices for oversight of omnibus accounts maintained by broker-dealers are evolving.
    • EFFECTIVE INTERMEDIARYGOVERNANCEThe Changing Transfer Agency Paradigm• Direct accounts
    • EFFECTIVE INTERMEDIARYGOVERNANCEThe Changing Transfer Agency Paradigm• Direct accounts• Networking accounts
    • EFFECTIVE INTERMEDIARYGOVERNANCEThe Changing Transfer Agency Paradigm• Direct accounts• Networking accounts• Omnibus accounts
    • EFFECTIVE INTERMEDIARYGOVERNANCEFrom Policies and Procedures to Governance• From direct responsibility. . .• To acting more indirectly
    • EFFECTIVE INTERMEDIARYGOVERNANCEOmnibus Recordkeepers Must Demonstrate That They:• Operate in an environment that makes it likely that they will fulfill their responsibilities.• Have established adequate controls over the recordkeeping processes.• Are complying with fund requirements.
    • EFFECTIVE INTERMEDIARYGOVERNANCEEvolving Best Practices1. Establish a working group assigned to intermediary governance
    • EFFECTIVE INTERMEDIARYGOVERNANCEEvolving Best Practices1. Establish a working group assigned to intermediary governance2. Establish an oversight committee
    • EFFECTIVE INTERMEDIARYGOVERNANCEEvolving Best Practices1. Establish a working group assigned to intermediary governance2. Establish an oversight committee3. Develop a risk matrix or scorecard for evaluating omnibus intermediaries and recordkeepers
    • EFFECTIVE INTERMEDIARYGOVERNANCEEvolving Best Practices1. Establish a working group assigned to intermediary governance2. Establish an oversight committee3. Develop a risk matrix or scorecard for evaluating omnibus intermediaries and recordkeepers4. Communicate early and often with fund boards
    • EFFECTIVE INTERMEDIARYGOVERNANCEEvolving Best Practices1. Establish a working group assigned to intermediary governance2. Establish an oversight committee3. Develop a risk matrix or scorecard for evaluating omnibus intermediaries and recordkeepers4. Communicate early and often with fund boards5. Use FICCA framework
    • EFFECTIVE INTERMEDIARYGOVERNANCEDisclaimerAlthough the observations and conclusions contained in this white paper representthe best thoughts of the individuals comprising the NICSA Intermediary DiscussionForum, they do not necessarily reflect the views of NICSA or any of its memberorganizations. Nothing herein is intended to be or should be construed as legal advice.You should contact your own counsel in order to obtain legal advice regarding these orany other matters.