Interpretation of regulatory rules and guidance for an international investment banking group
Defining parallel and similar processes for global
equity reporting purposes
• The Client was a global investment bank with a
major UK trading operation. The client was
expanding by acquisition and new clients trading
in the emerging markets. The existing
methodology used for the calculation of equity
positions held relied on a heavily manual process
and many aspects of international co-operation.
• This was coupled with a lack of systems
infrastructure and manual completion of
A firm is required to report to the FSA (the UK regulator at
the time) when their trading of a stock crosses a
threshold on purchase or disposal, including
connected persons, person discharging managerial
responsibility & directors.
• The Panel on Takeovers and Mergers (the “Panel”)
is an independent body, established in 1968,
whose main functions are to issue and administer
the City Code on Takeovers and Mergers (the
“Code”) and to supervise and regulate takeovers
and other matters to which the Code applies.
• Its central objective is to ensure fair
treatment for all shareholders in
• CEI Compliance were asked to provide a solution
to support the project and provide a central point
of contact as well as interface with the
compliance and risk IT departments.
• Half-way through the project, after identifying
the scalability, the scope was increased to
accommodate worldwide equities for global
reporting to enable the investment
research team to provide accurate
conflict of interest disclosures
• The UK Regulator expected Disclosure and
Transparency reports to be made at certain
thresholds of positions taken or disposed of.
• The Panel for Takeovers and Mergers equally
expected certain declarations to be made for
impacted parties or related holdings, or the
bank could have been in breach of the rules.
• The solution was to install a Compliance Business
Analyst within the project to work with the
project manager and direct the developer on the
process flow, exceptions and exceptions of the
two reporting requirements as well as the on the
project. The BA then grew the processes and
translated them for the developer to design
the system and user interface and provide
automatic completion of the standardised
forms for transmission by compliance
after their approval on the go/
no go function and final
amendment if trades had been
altered post report running.
• The Investment Research element required
identification of trading entities, systems and
holdings that would impact the reporting
requirements other than UK or dual listed
• The roll out to the worldwide community was
commenced after the parameters and
specifications had been agreed, with
the bank staff finalising the inputs.
• The overall result was an extremely successful
project that delivered on time and within budget
against a revised plan. The client was able to
switch on the new methodology and use this in
the course of regular trading and risk
• The new methodology enabled the client to
more accurately identify their trading
positions as well as improve the
capacity to provide reports to the
interested parties with confidence
• Total time spent 10 months.
• Resource Cost £264,000
• Internal Cost approx. £350,000
• Senior Management sleep value - priceless
• You are always dealing with the principal when
you are dealing with my firm. This means that I am the
relationship manager and there is no junior partner to
whom responsibility will be transferred. There is no
decreased accountability, no "hand-off" to a lessinformed colleague. If your interests are at stake
continually, shouldn’t you reasonably expect my
• We can usually provide resources on a "just in
time" basis. That is, our projects do not have to cover
excessive overhead, such as multiple offices, large
administrative backup, recruiting, partner perks, etc.
We are organized to efficiently provide everything that
you, as the buyer needs, but nothing more than that
which means that you are paying for value and results
and only minimum overhead.
• There is more likelihood of your privacy
and confidentiality being observed with
fewer people working on the project. We
(and/or the few people we might also involve)
are constant which means that there isn’t the
need to sift through dozens of differing
• We’re faster. We can respond to requests
quickly, and return all calls within four hours
which means to you that there is no need to
worry about a bureaucracy, delays and
unknown people on the other end of the
• Since we handle fewer concurrent projects than
larger firms, our attention is focused on the job at
hand. This means that you don’t have to
"compete" with another dozen or so of our
clients, which may be larger, paying more or are
more time-demanding. We structure our work so
that every client receives maximum
• Your investment is controlled. There is no
"meter running". We work for a fixed, valuebased, project fee. Large firms can’t afford to do
that as readily because of all the people involved
and their own insistence on measuring their
success by billable hours. We measure our success
by client objectives reached, not in “time units”.
• The expertise that larger firms use is often whitelabelling for them by a pool of consultants
available in the marketplace at any one time. We
select our consultants from practising
subject matter experts which means that
you obtain the same or better expertise for less
• Inevitably, we are less expensive. There
are economies to using someone who can base
their fees on each situation and not on a predetermined service scale or need for reaching a
practice quota. This means quite simply better
value to you.
Click Mouse Reveal Next Phase
We will conduct an initial appraisal at our cost
– only charging for expenses (UK only)
We will make a proposal based on our
appraisal with your outcomes and needs
We will discuss the precise scope with you
and provide you with a project price
We will complete the work to your original
scope and satisfaction
We have a wealth of Financial Services Experience, and due to
the remedial and sensitive nature of our work forming over 60%
of our business and that is conducted under a Non Disclosure
Regime, we cannot demonstrate every client.
We Do have a large
amount of experience in a
number of other fields and
industries within the major
utilities and even Local
We can provide all manner of assistance in
• Initial risk assessment or audit — an initial analysis to
identify higher risk areas of the business and weaknesses
in procedures. We also do risk management design.
• Business development — business analysis advice or
advice on particular issues — for example, how your firm is
Treating Customers Fairly and an action plan for
implementing Conduct Risk across your business.
• Help with setting up procedures — for example procedural
manuals for recruitment, training and competence,
complaints handling and anti-money laundering. May also
include templates for disclosure documents, fact-finds and
• File audits — checks to ensure that procedures are being
followed and identify good practices and weaknesses
• Complaints Handling – cost effective and project managed
from start to finish making your response robust and
• Technical support — may include advice on particular
products or regulatory reporting. May be available in
various formats, including website, helpdesk and
individual technical advice.
• Training — for example competency assessments,
training opportunities or product risk guidance. May
be online support, regulatory updates or seminar
• Support on individual issues — for example in
dealing with a complaint, a financial promotion or a
particular suitability letter.
• Financial promotions (all areas of advertisement) full support which would include websites, brochures,
DVD's, email templates, client mail shots, adverts,
contacting existing clients and so on.
• Remedial work — helping to action remedial work
required by the FCA/PRA.
• And much more … just ask!
Tel +44 7092
We operate across the UK, Europe
and the Middle East.
Currently exploring opportunities in