Recently, the SEC adopted new rules to require certain key market participants to have comprehensive policies and procedures in place surrounding their technology (Regulation SCI).
Exchanges, SROs, selected alternative trading systems (ATS), plan processors, and exempt clearing agencies are required to design, develop, test, maintain, and oversee their mission-critical systems.
The rules require them to ensure that their core technology meets certain standards, conduct regular business continuity testing, and provide certain notifications in the event of systems disruptions, intrusions and other events.
Meeting the demanding new requirements imposed upon firms by SEC Regulation SCI is a key issue for many market participants, especially in the areas of independent systems testing and certification.
Tellefsen and Company, L.L.C. (Tellefsen) and Exactpro Systems, LLC (Exactpro) have today announced a marketing partnership in which both firms will collaborate to provide key industry constituents with market structure consulting, financial technology infrastructure testing and software quality assurance testing services.
SEC Regulation SCI, ARP Reviews and AuditsJohn Rapa
The document discusses the SEC's proposed Regulation SCI which would require certain key market participants like exchanges and clearing agencies to implement comprehensive policies around their technology. It would replace voluntary guidelines with enforceable rules around areas like systems design, testing, and incident response. Recent market events showed technology failures can impact investors and market confidence. The new rules are aimed at reducing technology problems and ensuring proper response if issues do occur. Tellefsen & Company has expertise in helping clients comply with such regulations through activities like automation reviews, testing, and regulatory filings.
Risk & Compliances Officers globally are putting 1000’s of man-hours to collate global regulatory intelligence relevant to their business and even more time to track changes without dedicated research team experienced in global regulatory framework; thus increasing costs of compliance and risks of non compliance.
Lawrbit Global regulatory intelligence is created and continuously updated with regulatory changes through collaborative input of 1000s of legal experts from 100+ law firm across 80+ countries. Lawrbit provides a centralized repository of all required regulatory know how that can be commonly accessed by Compliance Officers, Functional Users, Management, Board of Directors and Auditors.
Drive compliance culture to ensure 100% adherence & lower risks with LexComply Legal Compliance Management solution in India, having integrated technology & updated legal library to identify, Allocate, Report & monitor compliance across group companies, locations, departments, & 3rd parties.
Citifyd offers a mobile-based premium parking platform that allows teams and venues to sell parking passes, collect sponsorship dollars, and gain operational insights. Their limited time offer provides a season-long pilot test at no upfront cost, with Citifyd taking a 10% convenience fee on parking pass sales. The platform aims to improve the fan experience through proximity marketing, cashless ingress, customized notifications, and flexible parking options while increasing revenue, fan data, and efficiency for teams and venues.
This document outlines the key steps in the securities trade life cycle from order origination to settlement. It describes the roles of different departments within a brokerage firm or securities trading organization, including the front office for order origination, middle office for order validation and confirmation, and back office for clearing and settlement. The life cycle involves order entry, execution, reconciliation, confirmation, booking, accounting, cashiering and settlement functions to complete a trade.
Tellefsen and Exactpro Systems Team Up to Help Clients with REG SCI
Meeting the demanding new requirements imposed upon firms by SEC Regulation SCI
is a key issue for many firms, especially in the areas of independent systems testing
and certification. Tellefsen and Company, L.L.C. (Tellefsen) and Exactpro Systems,
LLC (Exactpro) have today announced a marketing partnership in which both firms will
collaborate to provide key industry constituents with market structure consulting, financial
technology infrastructure testing and software quality assurance testing services.
Tellefsen is a management consulting firm founded in 1984 to provide counsel and
professional services to meet the growing needs of the financial services industry. The
firm’s principals and consultants have a wealth of experience in regulatory compliance
and U.S. market infrastructure (exchanges, ATS, dark pools etc). One of Tellefsen’s core
competencies has been is assisting firms with their regulatory compliance requirements
through technology analysis, planning, testing, and evidencing.
Exactpro is a rapidly growing quality assurance services firm specializing in market
infrastructure. Exactpro provides both functional and non-functional testing for global
exchanges, dark pools and clearing houses using a range of sophisticated in-house built
testing and evidencing tools.
John Rapa, President and CEO of Tellefsen, indicates: “The implementation of Reg SCI
is another example of market regulations where market participants must provide evidence
of their comprehensive infrastructure testing, policies and procedures and market oversight
compliance. We are delighted to team up with Exactpro whom we know from other customer
engagements. We are very impressed by their capabilities, diligence and effectiveness in
planning, executing and evidencing tests that prove regulatory compliance”.
Iosif Itkin, Co-Founder of Exactpro, says: “Our firm has a great set of tools and services that
we believe can help clients meet Regulation SCI in a cost effective manner. We are very
conversant with this domain and are delighted to be working with Tellefsen on this; our two
firms’ capabilities are entirely complementary”.
CH&Co - Supporting the development and adoption of RegTechNicolas Heguy
This presentation was submitted in January 2016 as an answer to the UK Financial Conduct Authority’s Call for Input on Regtech.
We’re publishing it also here to foster wider discussion on development and adoption of RegTech in the UK.
Special thanks to @Stephane_eyraud, @Patrick_bucquet, @Ekaterina_diakonova, @Sebastien_meunier and @Jean-stephane_gourevitch
SEC Regulation SCI, ARP Reviews and AuditsJohn Rapa
The document discusses the SEC's proposed Regulation SCI which would require certain key market participants like exchanges and clearing agencies to implement comprehensive policies around their technology. It would replace voluntary guidelines with enforceable rules around areas like systems design, testing, and incident response. Recent market events showed technology failures can impact investors and market confidence. The new rules are aimed at reducing technology problems and ensuring proper response if issues do occur. Tellefsen & Company has expertise in helping clients comply with such regulations through activities like automation reviews, testing, and regulatory filings.
Risk & Compliances Officers globally are putting 1000’s of man-hours to collate global regulatory intelligence relevant to their business and even more time to track changes without dedicated research team experienced in global regulatory framework; thus increasing costs of compliance and risks of non compliance.
Lawrbit Global regulatory intelligence is created and continuously updated with regulatory changes through collaborative input of 1000s of legal experts from 100+ law firm across 80+ countries. Lawrbit provides a centralized repository of all required regulatory know how that can be commonly accessed by Compliance Officers, Functional Users, Management, Board of Directors and Auditors.
Drive compliance culture to ensure 100% adherence & lower risks with LexComply Legal Compliance Management solution in India, having integrated technology & updated legal library to identify, Allocate, Report & monitor compliance across group companies, locations, departments, & 3rd parties.
Citifyd offers a mobile-based premium parking platform that allows teams and venues to sell parking passes, collect sponsorship dollars, and gain operational insights. Their limited time offer provides a season-long pilot test at no upfront cost, with Citifyd taking a 10% convenience fee on parking pass sales. The platform aims to improve the fan experience through proximity marketing, cashless ingress, customized notifications, and flexible parking options while increasing revenue, fan data, and efficiency for teams and venues.
This document outlines the key steps in the securities trade life cycle from order origination to settlement. It describes the roles of different departments within a brokerage firm or securities trading organization, including the front office for order origination, middle office for order validation and confirmation, and back office for clearing and settlement. The life cycle involves order entry, execution, reconciliation, confirmation, booking, accounting, cashiering and settlement functions to complete a trade.
Tellefsen and Exactpro Systems Team Up to Help Clients with REG SCI
Meeting the demanding new requirements imposed upon firms by SEC Regulation SCI
is a key issue for many firms, especially in the areas of independent systems testing
and certification. Tellefsen and Company, L.L.C. (Tellefsen) and Exactpro Systems,
LLC (Exactpro) have today announced a marketing partnership in which both firms will
collaborate to provide key industry constituents with market structure consulting, financial
technology infrastructure testing and software quality assurance testing services.
Tellefsen is a management consulting firm founded in 1984 to provide counsel and
professional services to meet the growing needs of the financial services industry. The
firm’s principals and consultants have a wealth of experience in regulatory compliance
and U.S. market infrastructure (exchanges, ATS, dark pools etc). One of Tellefsen’s core
competencies has been is assisting firms with their regulatory compliance requirements
through technology analysis, planning, testing, and evidencing.
Exactpro is a rapidly growing quality assurance services firm specializing in market
infrastructure. Exactpro provides both functional and non-functional testing for global
exchanges, dark pools and clearing houses using a range of sophisticated in-house built
testing and evidencing tools.
John Rapa, President and CEO of Tellefsen, indicates: “The implementation of Reg SCI
is another example of market regulations where market participants must provide evidence
of their comprehensive infrastructure testing, policies and procedures and market oversight
compliance. We are delighted to team up with Exactpro whom we know from other customer
engagements. We are very impressed by their capabilities, diligence and effectiveness in
planning, executing and evidencing tests that prove regulatory compliance”.
Iosif Itkin, Co-Founder of Exactpro, says: “Our firm has a great set of tools and services that
we believe can help clients meet Regulation SCI in a cost effective manner. We are very
conversant with this domain and are delighted to be working with Tellefsen on this; our two
firms’ capabilities are entirely complementary”.
CH&Co - Supporting the development and adoption of RegTechNicolas Heguy
This presentation was submitted in January 2016 as an answer to the UK Financial Conduct Authority’s Call for Input on Regtech.
We’re publishing it also here to foster wider discussion on development and adoption of RegTech in the UK.
Special thanks to @Stephane_eyraud, @Patrick_bucquet, @Ekaterina_diakonova, @Sebastien_meunier and @Jean-stephane_gourevitch
Six Keys to Securing Critical Infrastructure and NERC ComplianceLumension
With the computer systems and networks of electric, natural gas, and water distribution systems now connected to the Internet, the nation’s critical infrastructure is more vulnerable to attack. A recent Wall Street Journal article stated that many utility IT environments have already been breached by spies, terrorists, and hostile countries, often leaving bits of code behind that could be used against critical infrastructure during times of hostility. The U.S. Cyber Consequence Unit declared that the cost of such an attack could be substantial: “It is estimated that the destruction from a single wave of cyber attacks on U.S. critical infrastructures could exceed $700 billion USD - the equivalent of 50 major hurricanes hitting U.S. soil at once.”
Vulnerability and exposure of utilities’ critical infrastructures originate from the Supervisory Control and Data Acquisition (SCADA) and Distribution Automation (DA) systems that communicate and control devices on utility grids and distribution systems. Many of these systems have been in operation for years (sometimes for decades), and are not designed with security in mind. Regulatory bodies have recognized the many security issues to critical infrastructure and have begun to establish and enforce requirements in an attempt to shore up potential exposures. One such regulation is NERC CIP, which includes eight reliability standards consisting of 160 requirements for electric and power companies to address. And as of July 1, 2010, these companies must be “auditably compliant” or else they risk getting slapped with a $1 million per day, per CIP violation.
In this roundtable discussion, we will highlight:
• The security challenges facing utilities today
• The six critical elements to achieving economical NERC CIP compliance
• How utilities can secure critical infrastructure in today’s networked environment
Enterprise Governance Risk and Compliance (GRC) Management Solution in IndiaLexComply
Having most comprehensive coverage of compliance amongst the available GRC solutions in India, we ensure you don’t miss any compliance or legal updates . Know all you need about compliance in a single screen.
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This document proposes an approach to automate key activities in the security compliance value chain. It discusses automating the interpretation of PCI-DSS regulations to identify system requirements, tracing these requirements to CIS security controls, implementing appropriate controls, and verifying and reporting compliance. The approach uses a rule model to interpret regulations and classify them based on rule intents and acts. It applies natural language processing to 209 PCI-DSS regulations and traces 189 technological regulations to over 400 CIS security controls for Windows Server 2008. An evaluation achieves 80-83% precision and recall in automated interpretation.
The document discusses regulatory requirements for trade reporting and monitoring from FINRA, NASDAQ, and other agencies. It covers requirements around accepting trades within 20 minutes on NASDAQ, reporting trades to the Order Audit Trail System (OATS) according to specific data elements and timestamps. FINRA can measure compliance for OATS and TRACE (Trade Reporting and Compliance Engine) based on metrics like late submissions and unmatched reports. The document also provides an example audit approach and discusses direct market access (DMA) tools, associated risks, and evolving governance/regulations.
This document discusses SOC 1 and SOC 2 reporting for third party processors. It explains that user organizations are increasingly requiring third party processors to obtain assurance reports on controls related to processes and information security. SOC 1 reports provide assurance on controls related to financial reporting, while SOC 2 reports provide assurance on controls related to security, availability, processing integrity, confidentiality, and privacy. The document outlines revisions made in 2014 to the SOC 2 standard to increase clarity, eliminate redundancy, and update criteria for changing technology and business environments.
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Banks must meet more (and more varied) regulations today than ever. The sheer scale and scope of banking regulations, including Dodd-Frank, Basel III and IFRS, pose challenges to all financial institutions, from the smallest bank to the largest financial services enterprise.
A Summary of Top 28 areas covered by EC Proposed Regulation for CRR, CRD IV and Basel III Regulatory Compliance and Implementation of the proposal: A publication by James Jeffrey Okarimia
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James J Okarimia
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Aligning Finance, Risk and Data Analytics in Meeting the Requirements of Emerging Regulations
Banks must meet more (and more varied) regulations today than ever. The sheer scale and scope of banking regulations, including Dodd-Frank, Basel III and IFRS, pose challenges to all financial institutions, from the smallest bank to the largest financial services enterprise.
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Banks must meet more (and more varied) regulations today than ever. The sheer scale and scope of banking regulations, including Dodd-Frank, Basel III and IFRS, pose challenges to all financial institutions, from the smallest bank to the largest financial services enterprise.
This document discusses key financial regulations and trends, and how technology can help financial institutions comply with regulatory reporting requirements. It outlines several major regulations including FATCA, Dodd Frank Act, Basel III, FINRA, AML, KYC, and MiFID. For each regulation, it provides high-level details on requirements and highlights. It also discusses challenges of regulatory compliance and how technology can help with tasks like data management, analytics, reporting automation and process consolidation to improve regulatory reporting.
This document provides guidance for auditors on auditing systems development life cycles (SDLC). It outlines the key steps auditors should take which include: developing an audit plan; identifying audit objectives and scope; collecting background information on the organization's IT systems and SDLC methodology; assessing materiality and risks; identifying controls implemented in each SDLC stage; and confirming the audit approach. The goal is to help auditors structure their review to provide assurance that systems are developed according to the organization's needs in an efficient and controlled manner.
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The US financial markets have evolved significantly from 2000 to 2014. Exchanges consolidated through mergers and acquisitions, leading to a duopoly of NYSE and NASDAQ. Electronic trading replaced much of the open-outcry model. New entrants like dark pools and alternative trading systems fragmented the markets. Regulation increased with rules like Reg NMS and Dodd-Frank. Technological advances enabled high-frequency and algorithmic trading. Clearing houses also consolidated while taking on more product types like OTC derivatives. The financial crisis of 2008 further accelerated these trends of consolidation, electronic trading, and increased regulation of the US markets.
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With the computer systems and networks of electric, natural gas, and water distribution systems now connected to the Internet, the nation’s critical infrastructure is more vulnerable to attack. A recent Wall Street Journal article stated that many utility IT environments have already been breached by spies, terrorists, and hostile countries, often leaving bits of code behind that could be used against critical infrastructure during times of hostility. The U.S. Cyber Consequence Unit declared that the cost of such an attack could be substantial: “It is estimated that the destruction from a single wave of cyber attacks on U.S. critical infrastructures could exceed $700 billion USD - the equivalent of 50 major hurricanes hitting U.S. soil at once.”
Vulnerability and exposure of utilities’ critical infrastructures originate from the Supervisory Control and Data Acquisition (SCADA) and Distribution Automation (DA) systems that communicate and control devices on utility grids and distribution systems. Many of these systems have been in operation for years (sometimes for decades), and are not designed with security in mind. Regulatory bodies have recognized the many security issues to critical infrastructure and have begun to establish and enforce requirements in an attempt to shore up potential exposures. One such regulation is NERC CIP, which includes eight reliability standards consisting of 160 requirements for electric and power companies to address. And as of July 1, 2010, these companies must be “auditably compliant” or else they risk getting slapped with a $1 million per day, per CIP violation.
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2. SEC Regulation SCI -
Systems Compliance and Integrity
On November 19, 2014 the SEC adopted new rules to require
certain key market participants to have comprehensive policies
and procedures in place surrounding their technology (Reg SCI).
Regulation SCI under the Securities Act of 1934 (“Systems
Compliance and Integrity”) replaces the current voluntary ARP
compliance program with rules whose violation of which may be
the subject to enforcement actions.
SROs, selected alternative trading systems (ATS), plan processors,
and exempt clearing agencies are required to design, develop,
test, maintain, and oversee their mission-critical systems.
The rules require them to ensure that their core technology meets
certain standards, conduct regular business continuity testing, and
provide certain notifications in the event of systems disruptions,
intrusions and other events.
Tellefsen and Company, L.L.C.
2013-2015
3. Tellefsen and Company, L.L.C.
2013-2015
High-profile technical glitches in the securities markets including
those that arose during the 2010 Flash Crash, the initial public
offerings of Facebook and BATS Global Markets as well as the
Knight Capital trading incident have illustrated that investors can
be at risk when technology fails, and confidence in the markets
can falter.
The market closures following Hurricane Sandy in 2012 also
highlighted the importance of having a robust market technology
infrastructure.
These events, subsequent discussions and commentary from a
cross section of market participants have helped shape the
development of the new rulemaking.
Reg SCI (Cont’d) …
4. Tellefsen and Company, L.L.C.
2013-2015
The new regulations will present challenges to the Chief
Technology Officer and especially the Chief Compliance Officer,
who is responsible for the creation and enforcement of reasonable
supervisory procedures related to the implementation and
maintenance of applicable HW/SW/NW technologies and
infrastructure.
While these responsibilities are far from a routine compliance skill
set, Reg. SCI is a continuation of a trend by the SEC of placing
increased responsibility on compliance with respect to policies and
procedures for implementing and maintaining various types of
technology.
For the past two decades, SROs have followed a voluntary set of
principles articulated in the SEC’s Automation Review Policy and
participated in what is known as the ARP Inspection Program.
Reg SCI now supersedes this (see final rulemaking in the Federal Register:
https://www.federalregister.gov/articles/2014/12/05/2014-27767/regulation-systems-compliance-
and-integrity)
Reg SCI (Cont’d) …
5. Tellefsen and Company, L.L.C.
2013-2015
The rulemaking was largely adopted as proposed, with the following
revisions and exceptions:
The proposed 30 day advance reporting requirement was changed
to quarterly.
The Direct Access requirement which would have required SCI
Entities to provide SEC staff with remote or on-site access to SCI
Systems was not adopted.
Safe Harbor protection from liability is limited to those individuals
who reasonably discharge their responsibilities under Reg SCI.
Senior management involved in the annual Reg SCI review will be
required to certify that they have implemented policies and
procedures reasonably designed to ensure compliance with the
rulemaking.
Reg SCI – Final Rulemaking
6. Tellefsen and Company, L.L.C.
2013-2015
Core technology of national securities exchanges, self-regulatory
organizations, significant alternative trading systems, clearing
agencies, and plan processors meets certain standards.
That these entities conduct regular business continuity testing with
their members or participants.
That they provide certain notifications regarding systems
disruptions, intrusions and other types of systems issues.
The probability of technology problems is reduced, and key entities
are well-positioned to take appropriate, corrective action when
problems occur.
Reg SCI Is Designed to Ensure:
7. Tellefsen and Company, L.L.C.
2013-2015
The proposed rule would apply to “SCI Entities” such as:
– Self-regulatory organizations (the registered national securities
exchanges, registered clearing agencies, FINRA, and MSRB).
– Alternative Trading Systems that exceed specified volume thresholds
(SCI ATS).
– Disseminators of market data under certain National Market Systems
plans (“plan processors”).
– Certain clearing agencies exempt from SEC registration.
It would apply primarily to the systems of SCI Entities that are core
to the functioning of the securities markets, such as those that
directly support trading, clearance and settlement, order routing,
market data, regulation, or surveillance.
The SEC anticipates that 14 ATSs will be required to be compliant.
It is unknown whether other business systems such as a shared
drive system or phone system are within the scope.
Reg SCI – Applicability
8. Tellefsen and Company, L.L.C.
2013-2015
Establish policies and supervisory procedures relating to the
capacity, integrity, resiliency and security of its technology systems.
Ensure its systems operate in the manner intended, including in
compliance with relevant federal securities laws and rules.
Take timely corrective action in response to systems disruptions,
systems compliance issues and systems intrusions.
Notify and provide the SEC with detailed information when such
systems issues occur, systems intrusions, and when there are
material changes in its systems. Written notices of “SCI Events” will
be reported to members and market participants and filed
electronically to the SEC on Form SCI.
Inform its members or participants about certain systems problems
and provide information about the systems and market participants
affected by the problem and the progress of corrective action.
SCI Entities - Requirements:
9. Tellefsen and Company, L.L.C.
2013-2015
Provide quarterly notice to the SEC of any material system changes,
including completed, ongoing and planned material changes to SCI
systems and the security of indirect SCI systems, during the prior,
current and subsequent calendar quarters.
Conduct an annual review of its compliance with Regulation SCI, and
submit a report of the annual review to its senior management and
the SEC.
Plan and engage in annual business continuity and disaster recovery
testing.
Designate certain individuals or firms to participate in the testing of
its business continuity and disaster recovery plans, and coordinate
such testing with other entities on an industry- or sector-wide basis.
Demonstrate systems testing, test results and related capabilities to
SEC staff on-site during inspections.
SCI Entities Requirements (Cont’d)…
10. Tellefsen and Company, L.L.C.
2013-2015
The SEC has granted Safe Harbor protection from liability to
individuals within SCI Entities who reasonably discharge their Reg
SCI compliance responsibilities under their policies, procedures and
controls.
Reg SCI is effective 60 days after publication in the Federal Register,
and SCI Entities must comply with the requirements within 9 months
of the effective date.
ATSs that satisfy volume threshold levels for the first time will be
granted an additional 6 months from that time to comply.
SCI Entities will have 21 months from the effective date to comply
with the industry or sector wide BC/DR testing requirement.
SCI Entities Requirements (Cont’d)…
11. Tellefsen and Company, L.L.C.
2013- 2015
Reg SCI entities need to ensure their written policies and
procedures are up to date.
Problem tracking systems must actively capture problems, problem
identification, cause/effect and resolution.
Regular reporting to the SEC is required:
– Ad-hoc incident reporting
– Quarterly reports of planned and material system changes
– Annual Reg SCI Review
Policies, Procedures and Reporting
12. Tellefsen and Company, L.L.C.
2013- 2015
Reg SCI entities need a comprehensive testing regimen in order to
be compliant.
Functional and non-functional testing of applicable Reg SCI
ecosystems.
Comprehensive test regimens for quality assurance, regression,
capacity, stress, failover/recovery, user acceptance etc.
Development and maintenance of a test repository and active
analysis of production data.
Need for industry insight and domain market structure expertise in
the design, planning and execution of industry test initiatives.
Independent test execution, oversight and reporting.
Assistance with preparation of annual Reg SCI compliance report to
SEC.
Reg SCI Testing and Oversight
13. Tellefsen and Company, L.L.C.
2013-2015
Tellefsen and Company (TCL) has a market structure practice and
core competency and depth of experience in assisting exchanges,
clearing houses and ATS in complying with regulatory guidelines.
We have conducted numerous technology reviews for clients in the
last several years, including investment management firms, ATS,
clearing houses and exchanges.
We have also counseled and guided our clients through the
preparation for regulatory designation reviews and inspections by
the CFTC, FINRA and the SEC.
Our mission-critical systems expertise includes trading systems,
market data dissemination, clearing, risk management and market
surveillance components.
Tellefsen and Company –
Automation Review Expertise
14. Tellefsen and Company, L.L.C.
2013- 2015
Experience with prior client assignments has included the
development of testing, compliance documentation and procedures
for trading and operations management, including:
Business impact analysis
Business continuity management
Capacity planning
Systems development methodology
Acceptance testing
Configuration and release management
Network management
Problem management/problem tracking
Information and physical security
Failover, stress and capacity testing
Market Structure, Compliance and
Automation Review Expertise
15. Tellefsen and Company, L.L.C.
2013 -2015
Our firm brings unique market insight and market micro structure
experience to client assignments
Development and audit of business continuity plans, systems
failover and fall back testing strategies and plans are a core
competency of our firm, as is systems quality assurance and
acceptance testing
We have provided independent test oversight and test results
attestation for various exchanges, clearing houses and numerous
market participants.
Market Structure Expertise (Cont’d) …
16. Tellefsen and Company, L.L.C.
2013- 2015
TCL has introduced a marketing partnership with Exactpro Systems,
a specialist FinTech firm focused on testing of mission-critical
trading systems and market infrastructure .
Started in 2009, Exactpro has experienced phenomenal growth as
satisfied clients consume more services - now employing over 280
specialists.
Headquartered in San Rafael, California, with four quality assurance
and development centers in Russia and sales support in the UK.
Clients include global exchanges, clearing houses, inter-dealer
brokers, investment banks, ATS, futures commission merchants,
order management/execution management system providers.
www.exactpro.com
Marketing Partnership with
Exactpro Systems
17. Tellefsen and Company, L.L.C.
2013- 2015
▀ Major equities and commodities futures exchanges
▀ Commodities futures clearing corporation
▀ ATSs with low latency trading platforms
▀ Swap Execution Facilities (SEFs)
▀ Global derivatives and futures commission merchant
▀ Investment bank specializing in emerging markets
▀ Equity broker-dealer offering program and single name execution
▀ Order management/execution management system provider to buy-
side and sell-side constituents
Exactpro Systems –
Prior Client Experience
18. Reg SCI Testing Expertise
Quality Assurance:
Test Planning and
Management
Latency and Capacity
Testing
Intelligent Management
of Large Data Sets
Process Audit and Test
Coverage Analysis
Automated Regression
Testing
Requirements Definition
and Test Scenario Creation
(human, message & reporting interfaces)
Intelligent Functional and
Exploratory Testing
Develop/Productize
state-of-the-art
Test Harnesses
Test Automation
Test Data Management
Protocol Level Testing via:
FIX/FAST, SOAP, HTTP, ITCH,
SWIFT, MQ, SQL, Proprietary
Binary and Text-based
Data Formats, etc.
19. Focused on the Lifecycle of Trading
Financial Products
Platforms Pre and Post Trade;
Commodities, Futures,
Derivatives,
Equities, Fixed Income, FX
Deal Capture &
Position Keeping
Risk Management
Middle Office
Clearing and
Settlement
Messaging
Reference Data
Order and Execution
Management
Market Venue
Connectivity
Smart Order
Routing
Algorithmic
Trading
Matching Engines
Market Data
Distribution
20. Exactpro’s Test Automation Suite
ClearTH:
• Post-Trade testing tool
• Verifies each stage of the DLC
• Integrated schedule
• Automated matrices
• Can create multiple days test
scenarios
• Concurrent multiple tests
• Integrated simulators
• SWIFT ISO protocol support
MiniRobots:
• Executes multithreaded java
code
• Complexity of test algorithms is
defined by the test developer
• Supports multiple client fix
connections, order entry and
market data via FIX
• Can use GUI to iterate through
sent and received messages
Dolphin:
• Model-based testing of market
surveillance systems
• Production-scale capacity and
throughput
• Interactive real-time alerts and reports
Shsha:
• Post-transactional tool
• Analyzes clients' activity and forecasts system response
• Parses and displays logs in a user-friendly way
• Parses messages and then puts each to a data base
table
where each column corresponds to each message field
• Allows making summarized reports, etc
• Easy to understand GUI
Load Injector:
• Simulates multiple client connections with a specified load shape
for each connection or a group of connections
• Up to 75K messages / second from a single CPU core
• Measures latencies in microsecond range
• Performance test reports
Sailfish:
• Can test Order Entry, Market Data and
Post Trade connections in one test scenario
• Each test scenario is independent
• Allows running test scripts in any sequence
• Simulation of multiple user connections
• Server simulators
• All messages are stored into a
data base
• Generates test reports
21. Applicability to Reg SCI
An experienced team, armed with the proper tools that can hit the ground
running to review, test and provide evidence in a cost effective fashion!
A range of well organized testing services that cover several of the
aspects essential for Reg SCI compliance
-
1. Conventional Non
Functional Testing:
• Load test to establish the
reasonable current and future
capacity planning estimates
• Capacity stress tests of
systems to determine their
ability to process transactions
in an accurate, timely, and
efficient manner
• Failover & recovery tests to
verify backup, contingency and
disaster recovery capabilities,
including geographically
diverse locations
2. Conventional
Functional Testing:
• Efficient testing to exercise
all key functionality and data
set-up
• Positive and negative tests
to identify vulnerabilities
pertaining to internal and
external threats, physical
hazards, and natural or
manmade disasters
• All test evidence per run
stored within an easy to
access and report test
repository
• Automated Regression
testing of subsequent releases
and reporting of all relevant
changes within the system
3. Testing at the
Confluence of
Functional and Non
Functional Testing:
• High frequency and
algorithmic trading activity
simulations
• Testing to assure
systems capacity, integrity,
resiliency, availability and
security under realistic
participants load
• Modeling of all data
inputs and outputs from
system to evaluate the
behavior within normal
operational and outage
scenarios
4. Production Data
Analysis:
• Capture and Analyze
data from production to
understand real usage
• Monitor and investigate
production events
• Feedback to refine test
coverage for subsequent
versions
• Bringing QA perspective
into operational support
22. For More Information, Contact
Tellefsen and Company, L.LC.
John Rapa
1-212 809 3800
JJR@Tellefsen.com
22