Panel Discussion - Exploring a New Era: Shareholder Authentication and Alternatives to Medallion Signature Guarantees
Moderator: Sandy Morris, American Century Investments
Panelists: Carrie Caruther, Priority Investors; Joya Favors, Northern Trust; Jay Sterling, Thrivent Financial
1. www.nicsa.org
NICSA – Midwest Regional Meeting
Panel Discussion - Exploring a New Era: Shareholder Authentication and
Alternatives to Medallion Signature Guarantees
September 22, 2015
2. www.nicsa.org
Jay Sterling, Manager & Assistant
Operations Officer
Jay is a Manager and Assistant Operations Officer for The Thrivent Mutual Funds
Transfer Agent.
His primary focus is on regulatory support and oversight for all Mutual Fund
operational functions.
Jay has 17 years of experience in the mutual fund transfer agent industry within 3
Midwest based companies.
He has served and participated on several industry steering committees including the
ICI Transfer Agent Advisory Committee as well as the Regulatory Compliance Advisory
Group with DST Inc.
3. www.nicsa.org
Carrie Caruthers, Risk & Fraud
Control Manager
Carrie just took over the role of Risk & Fraud Control Manager at American Century
Investments.
She has more than 16 years' experience working with direct clients and supporting
their investment goals. Carrie holds FINRA 6, 7, 63, 24 & 26 licenses.
Previously, Carrie was the Business Manager, Priority Investors, for American Century
Investments, overseeing the complex needs of brokerage and retail services, principle
oversight and Priority Program manager of the team dedicated to supporting high net
worth clients.
Carrie has worked closely with business partners in Legal, Risk & Fraud and Workforce
Operations to safeguard a client's financial interests by strengthening the overall
experience through increased authentication options with direct and indirect
interactions.
4. www.nicsa.org
Joya Favors, Vice President &
Control Manager
Joya Favors is a Vice President and Control Manager for Northern Trust Company. In
her role, Joya collaborates closely with the Transfer Agency management to ensure a
proactive focus on controls, works closely with internal and external audit partners,
and acts as a subject matter expert in Transfer Agency controls.
Prior to joining the Control team in 2012, Joya managed the Operations team for
Northern Trust’s North American Transfer Agency from 2007-2012. Joya also
represents Northern Trust as a NICSA Transfer Agency Committee Member.
Prior to joining Northern Trust in 2007, Joya served as a Transfer of Accounts Manager
at Mesirow Financial in Chicago. Previously, she worked as an ACATS Work Director at
Wells Fargo Investments in Minneapolis, MN.
She earned a Bachelor's degree in business and sociology from Fisk University in
Nashville, TN. She holds FINRA 7 and 63 licenses.
5. www.nicsa.org
Thrivent Mutual Funds
Business Model
• Fraternal benefits organization
− Member focused
• Captive sales force
– Approximately 2,500 Thrivent Financial
registered representatives
• Employees of the company
• Primarily a check and application shop
– 85% network level 0
– 10% omnibus
– 5% network level 3
• Cross product ownership
– High number of members own multiple
products
• Mutual Fund/Annuity/Life Insurance
Thrivent Financial Headquarters – Minneapolis, MN
Thrivent Financial Headquarters – Appleton, WI
6. www.nicsa.org
Thrivent Mutual Funds
Authentication Model
• Registered representatives
– Full name
– Registered representative #
– One of the following two
1. Member ID
2. Shareholder account #
• Shareholder
– Full name
– Two of the following three
1. DOB
2. Member ID
3. Shareholder account #
7. www.nicsa.org
Thrivent Mutual Funds Knowledge
Based Authentication
• When used?
– Enhanced security requested
– Failed primary authentication
• Contract with third party vendor
• Web based tool
– Enter shareholder information
– Series of questions
– Pass or fail?
8. www.nicsa.org
Thrivent Mutual Funds –
Signature Verifications
• MSG
• Notary Public
• Registered Representative
Attestation
– Notary or MSG is not an
absolute requirement
– Registered representative is
attesting that the identity has
been verified
– Registered representative
accepts liability
9. www.nicsa.org
American Century Investments
A Foundation for Success
• Founded in 1958 by James E. Stowers, Jr.
• Today we are one of the largest private
money managers in the U.S.
– More than $140billion* in total assets.
• Focused on superior investment
performance through active team-based
investment management.
• Mutual funds and investment management
expertise distributed through Intermediary,
Institutional, International and Individual
channels.
• Headquartered in Kansas City with offices
in Mountain View, CA; New York; London;
and Hong Kong.
* As of 9/8/2015
American Century Investments Headquarters
10. www.nicsa.org
Stowers Institute for Medical
Research - A Hope for Life
• Founded by Jim and Virginia Stowers in 1994
to benefit humankind through research on
genetic-based diseases, including cancer.
• One of the largest endowments in the world
among private basic biomedical research
institutions.
• Home to 21 independent research programs,
three technology development programs and
more than 350 scientists.
• Through our ownership structure, more than
40% of American Century’s profits have been
distributed to the Institute in support of
research to help cure genetically-based
diseases including cancer, diabetes and
dementia.
The Stowers Institute for Medical Research
11. www.nicsa.org
Shareholder Authentication –
Current State
• Standard Client Verification
– Identification and Verification (ID&V)
– Phone Verification with representative
• Online Authentication
– User name/password
– Challenge question
– One Time Security Code (OTSC)
• Exception Request Review
– Reimbursement / cost exceptions
– Policy / risk exceptions
– Graduated approval requirements
– Senior leadership visibility for larger financial risk requests
– Documentation / audit trail
• Additional Verification
– Additional level of security
– High risk transactions
– Information given
– Out of wallet questions
12. www.nicsa.org
Shareholder Authentication –
Future State
• Voice Bio-Metrics
– High cost product
– Enrollment process
– Additional resources to analyze participants and process
• Phone-Print Verification
– Analyzes phone numbers
– Call audio recognition
– Voice bio-metric options
• Critical Notification
– Enrollment process
– Text message
– Automated voice
14. www.nicsa.org
A Unique Business Focus
Northern Trust is a market leader in asset servicing and asset management solutions for
institutions and private clients around the globe.
Who we are
• A provider of fund administration, global custody, asset management,
wealth management, banking and personal fiduciary services.
• Clients in approximately 46 countries; Services in over 100 markets
• Worldwide staff: 15,000+
Global Fund Services
• Focus on investment managers and fund companies
• Global Transfer Agency Locations: Chicago, London, Dublin, Limerick, Guernsey,
Luxembourg, Bangalore
• North America Transfer Agency Clients: 95 (as of June 30, 2015)
North America Transfer Agency
Vehicles Supported
Mutual funds
LPs & LLCs
Common & collective funds
Alternative funds and funds-of-funds
North America Transfer Agency
Services Supported
Client Servicing
Investor Servicing
Intermediary Servicing
15. www.nicsa.org
Shareholder Authentication
Types of Funds Transfers Requiring Authentication
Authentication Methods
• Security Questions
• PIN/Password
• Medallion Signature Guarantee
• Callback
Cash Movement Non-Repetitive Maintenance Requests*
• Wire Transactions - Out
• Internal Transfers – between client’s
accounts/legal entities
• Outgoing check/ACH
• Direct Funds to Client
• Fee Payments
• Repetitive Transactions
• Standing Instructions
• Protected profiles
*For new or changes to existing
Callback
PIN/Password
Medallion
Signature
Guarantee
Security
Questions
16. www.nicsa.org
Shareholder Authentication: Industry Challenges
Industry challenges facing shareholder authentication
Some firms will not stamp a free form letter
Some firms will only prove a stamp if investor is one
of their clients
Some firms are only providing stamp for transfer of
securities
Prospectus contains a stamp requirement for
transactions that are not a transfer of securities
Maintenance and Transaction Forms
Alternative Ways to Request Transactions
Signature Validation Program (SVP)*
Alternative Verification Process - Callback
Possible Resolutions
Investors Obtaining a
Signature Guarantee
Stamp
*Designed for non-securities commercial transactions
OUR ORGANIZATION IS THE FOUNDATION FOR THESE THREE CRITICAL ELEMENTS.
WE ARE A PROFITABLE INVESTMENT FIRM WHO HAS ACHIEVED SUCCESS OVER 50 YEARS BY EXCLUSIVELY SERVING THE FIDUCIARY INTERESTS OF OUR CLIENTS, WHETHER THEY ARE INSTITUTIONS OR INDIVDIVUALS. OVER THE PAST 10 YEARS, WE HAVE GROWN OUR INSTITUTIONAL BUSINESS SUBSTANTIALLY, AND WE NOW MANAGE ALMOST $20 BILLION FOR INSTITUTIONS GLOBALLY.
WE ARE INDEPENDENT AND PRIVATELY OWNED, WITH A SUPPORTIVE OWNERSHIP STRUCTURE, WHICH HAS ALLOWED US TO CONTINUALLY INVEST IN OUR INVESTMENT BUSINESS IN SPITE OF THE UNPREDICATABILITY OF THE PUBLIC MARKETS. FOR EXAMPLE, OUR OWNERS HAVE DILUTED THEIR OWNERSHIP POSITIONS TO ALLOW US TO INCREASE OUR EQUITY COMMITMENT TO OUR INVESTMENT PROFESSIONALS AND IN 2008, WAIVED THEIR DIVIDEND TO ALLOW US TO REINVEST DURING THIS MARKET DOWNTURN.
WE ARE DRIVEN BY OUR ABILITY TO GENERATE ALPHA FOR OUR CLIENTS THROUGH FUNDAMENTAL ANALYSIS OF COMPANIES. ALL OF OUR INVESTMENT PROFESSIONALS ARE SOLEY COMPENSATED BASED UPON THEIR ABILITY TO GENERATE LONG-TERM PERORMANCE AND THROUGH EQUITY OWNERSHIP OF AMERICAN CENTURY.
FINALLY, WE ARE A VALUES BASED ORGANIZATION, WITHOUT ANY REGULATORY ACTIONS TAKEN AGAINST THE FIRM OR ITS SENIOR PROFESSIONALS IN OUR 50 YEAR HISTORY. OUR PRIMARY OWNER – THE STOWERS INSTITUTE FOR MEDICAL RESEARCH – IS THE SECOND LARGEST ORGANIZATION OF ITS KIND IN THE US (NEXT TO HOWARD HUGHES) AND OVER 40% OF OUR PROFITS GO DIRECTLY TO RESEARCH ON CURING CANCER AND OTHER GENE BASED DISEASES. THIS REINFORCES THIS CULTURE EVERY DAY.
OUR FOUNDATION IS BUILT ON MR. STOWERS BELIEF, THAT IF OUR CLIENTS ARE SUCCESSFUL, THEN IN TURN WE WILL BE SUCCESSFUL. THAT DOES NOT STOP WITH THEIR FINANCIAL SUCCESS, IT IS EXTENDED TO PROTECTING AND SAFEGUARDING THEIR FINANCIAL INTERESTES FROM FRAUDLENT BEHAVIORS.
WE PROVIDE DEFENSES ON BOTH ACCOUNT ACCESS POINTS, OVER THE PHONE AND THROUGH ONLINE CAPABILITIES.
WHEN WE ARE CONTACTED OVER THE PHONE, THERE ARE A FEW GATES A CALLER WILL PASS BEFORE SPEAKING WITH A REPRESENTATIVE.
STANDARD CLIENT VERIFICATION
ID&V (IDENTIFICATION AND VERIFICATION)
IN ORDER TO BE FULLY VERIFIED PRIOR TO SPEAKING TO A REPRESENTATIVE – MUST PASS 3 LEVELS OF VERIFICATION
PARTIALLY VERIFIED CALLER MUST COMPLETE VERIFICATION WITH REPRESENTATIVE
VERIFICATION OPTIONS
ANI MATCH
FULL OR LAST 4 SSN/TIN
STREET #
PHONE NUMBER ENTERED
CUT 40 SECONDS/PHONE CALL/ SAVED 2 FTE A YEAR
PHONE VERIFICATION WITH REPRESENTATIVE
TWO CATEGORY PROCESS PASSING 3 VERIFICATION QUESTIONS
STATEMENT VERSUS NON-STATEMENT
FOREIGN ADDRESS PROCESS REQUIRES 2 ADDITIONAL VERIFICATION QUESTIONS
ONLINE AUTHENTICATION
USER NAME/PASSWORD
REMEMBER COMPUTER
CHALLENGE QUESTION
NOT A REMEMBERED COMPUTER
ONE TIME SECURITY CODE
NOT A REMEMBERED COMPUTER
ADDITIONAL VERIFICATION FOR FORGOTTEN PASSWORD OR CHALLENGE QUESTION
PASSWORD – OTSC BY TEXT/PHONE (NO EMAIL OPTION)
CHALLENGE QUESTION – OTSC BY EMAIL/TEXT/PHONE
CONTACTING REPRESENTATIVE AND GOING THROUGH ADDITIONAL VERIFICATION PROCESS
MINIMIZE HOW THE INFORMATION IS SHARED SO THAT MULTIPLE INFORMATION IS NOT GIVEN VIA EMAIL THAT ALLOWS ACCESS TO ACCOUNT
EXCEPTION REQUEST REVIEW
REIMBURSEMENT/COST EXCEPTIONS
FEE WAIVERS
REIMBURSEMENT COSTS
POLICY/RISK EXCEPTIONS
BUSINESS POLICY IS WAIVED
GRADUATED APPROVAL
MONITARY THRESHOLDS
RISK LEVEL
MULTI-TOUCH
SENIOR LEADERSHIP VISABILITY
AWARENESS OF EXCEPTIONS
TURNOVER RISKS
DOCUMENTATION/AUDIT TRAIL
COST TRACKING OF REIMBURESMENTS/FEE WAIVERS
RECORD KEEPING
POLICY REVIEW
SIGNATURE MATCHING
PREVIOUS CALL TO COMPARE VOICES
NOTARY
ADDITIONAL VERIFICATION
ADDITIONAL LEVEL OF SECURITY
LEVERAGED WHEN SIGNATURE GUARENTEE OPTIONS AND LIMITED OR UNOBTAINABLE
AUTHENTICATION CONCERNS WHEN STANDARD VERIFICATION IS SUCCESSFUL
CREATING ADDITIONAL OBSTICALS TO HELP PREVENT FRAUD
NO EXCEPTIONS FOR FOREIGN ADDRESSES
HIGH RISK TRANSACTIONS
WIRE TO BOR
THIRD PARTY REDEMPTIONS FOR TIMELY REQUESTS SUCH AS EQUITY CLOSING
WAIVING BANKING HOLD TIMES
INFORMATION GIVEN
USERNAME
ACCOUNT NUMBER
OTSC
OUT OF WALLET QUESTIONS
PUBLICALLY AVAILABLE INFORMATION
TIMED QUESTION/ANSWER PERIOD
LOOKING FORWARD:
VOICE BIO-METRICS
MOST COSTLY OF ADDITIONAL AUTHENTICATION PROCESSES
ENROLLMENT PROCESS – CLIENTS MUST ENROLL IN THE SERVICE WHICH CAN BE LENGTHY TO COMPLETE
REQUIRES ADDITIONAL STAFFING TO HELP ANALYZE AND OVERSEE THE PROCESS
PHONE-PRINT VERIFICATION
ANALYZES INBOUND AND OUTBOUND PHONE NUMBERS
PHONE SPOOFING
CALL FORWARDING
CALL AUDIO RECOGNITION
LOCATION
VOICE BIO METRIC OPTIONS
VOICE DISTORATION
REPEATE OFFENDERS
CRITICAL NOTIFICATION
ENROLLMENT PROCESS
TEXT MESSAGING NOTIFICATION – QUICK AND EFFICIENT
AUTOMATED VOICE FOLLOW UP
MORE COST EFFECTIVE THAN OTHER OPTIONS AND CAN BE MANAGED IN HOUSE