1. Updating Procedures
PREPAID BY: KIM VAUGHAN

2. Overview
Sarbanes Oxley Act requires publicly traded companies to attest effectiveness of internal controls
Acquisition of Morgan Kegan
The new approved Operations template has a more detailed format.
Failed our last two internal audits
Need to be in compliance with fund companies trading policy & Financial Industry Regulator
Authorities (FINRA)

3. Introduction
•What is the purpose of a procedure
•3 years since we last updated procedures
•We’ve undergone substantial growth
•Need to update, condense and implement current procedures into the new template
•Need to pass internal audits
•Minimize the risk of possible losses

4. The Opportunity
Pass all audits
Minimize risk of possible losses
 Determine Right way vs wrong way
All three sites follow the same guidelines

5. Current Situation
•Workflow has doubled
•Error rate has increased
•Failed audits/large losses
•Miss communication across 3 sites
•My proposal
4.3
2.5
3.5
2.4
4.4
1.8
2 2
3
0
0.5
1
1.5
2
2.5
3
3.5
4
4.5
5
Memphis St. Petersburg Southfield
Error Rates
Error Rate Trades Processed Corrections Processed

6. Key Success Factors
Increase team process and communication
Improve quantity and quality
Increase employee knowledge
Updated training documents
Improve customer service

7. Analysis of Alternatives
•Communicate changes via email
•Expect employees to take notes on procedures
modifications during meeting instead of
having them documented in a manual
document.
•Not effective – will cause more errors
•Purpose of having a manual document in a
trading environment

8. Strategic Solution Option
Layout of new procedure template
 Table of Contents
 Summary – Introduction, client impact, What happens before & after this process
 Roles and Responsibilities – Who’s role complete this process, frequency, other departments
involved
 Skills & Access Required – Associate knowledge of systems required to complete task
 Step by step procedures –Include screen prints and caution side notes if needed.
Escalation & Exception Guidance – For situations that might fall out of the norm/who to escalate to
for unusually - situations
Supervisory Control – Internal audits conducted by supervisor to validate quality, input & output
Conclusion – Emphasized the importance of the process to avoids client and market impact

9. Benefits of Updating Procedures
•Training time for Employees
•Ensures Business Continuity
•Standardize Processes
•Delegate Tasks
•Ensure clients are getting the best customer
service
•Improve communication between various
departments
•Improves efficiency and productivity of
Employees and managers
•Helps create an internal control framework
•Helps further the mission and goals of the
company

10. Risk of Updating Procedures
Workflow Getting behind – If the daily workflow gets behind with the 3 of us devoting our time
to this project then the project will be set aside until workflow is caught up.
Possible Overtime - To help stay on track we might need to work some overtime to avoid falling
behind.
Quality Control – Test the procedure, make sure associates and management approve
procedure before uploading to SharePoint.
Successful project = Good planning + good communication

11. Risk of Not Updating Procedures
•Low productivity because of unclear
instruction.
•Unclear responsibilities can lead to duplicate
work or task left incomplete.
•Error rates increasing because of the changing
business or regulatory environment.
•Increased risk of errors

12. Recommendation
•Stakeholders interest vs. limited resources
•Over 50 procedures to update
•Divide up procedures and document who is working on what to avoid duplicates
•Should take around 6 months to complete
•Have weekly meetings/look for feedback from associates

13. People involved in project
Patrick McNulty - VP of Mutual Funds
Ashley Blaz - Supervisor of St. Petersburg
Cathy Patel-Smith – Supervisor of Southfield
Todd Grady – Supervisor of Memphis
Kelly Gardina – Project manager
Kim Vaughan – Associate in St. Pete
Stacey Hoffmann – Associate in Southfield
Emily Hartzel – Lead associate in Memphis

14. Task
Task – Provide expertise through experience
and knowledge to update procedure.
Kim - Will work on Mutual Funds Trading
procedures
Stacey – Will work on Mutual Fund Correction
procedures
Emily – Will work on Mutual Fund
Reject/management procedures

15. Action Plan
• Kim, Stacey & Emily will devote the first half of their day to their normal processing (trades,
corrections process reports). The second half of the day they will update the procedures for
Mutual Fund Trading, Correction and Rejects.
• Review current procedure and implement information into new template.
•Add screen prints to each step by step process
•Talk with associate’s who currently process reports if you have questions
•Once procedures is complete send to associate's who process task for review
•Submit for supervisor review
•Upload procedure to Mutual Fund Trading SharePoint

16. Weekly Meetings
• Kim, Stacey, Emily and Kelly will meet every Monday from 10:00-11:00 via video conference.
• Report what they accomplished from the week before
• Talk about any bumps in the road
• Go over the procedures to be updated this week
• Sending meeting minutes out to supervisors and VP

17. Benefits of Solution
By updating our department procedures it help us differentiate the right vs wrong way to
process a task which will then:
Clear up confusion and have all three sites following the same guidelines
 Reduce errors charged to the department
Provide customer service with a service first attitude
Most importantly, be in compliance with fund companies policies and FINRA.

18. References
• Accounting Management Solutions, Inc. (2014) (Policies and Procedures)
http://www.amsolutions.net/articles/policies-and-procedures-leaving-you-open-to-
unnecessary-risk
• Banach, A. (2014) How to maintain & Update Policies & Procedures
http://everydaylife.globalpost.com/maintain-update-policies-procedures-10874.html
• Section 404(b) of Sarbanes-Oxley Act of 2002
http://www.aicpa.org/advocacy/issues/pages/section404bofsox.aspx

19. Continued References
• May, K. (2014) What Are the Causes of Low Levels of Productivity? (Small Business)
http://smallbusiness.chron.com/causes-low-levels-productivity-37959.html
• Weigers, K. (2014) 21 Projects Management Success Tips
http://www.projectsmart.co.uk/21-project-management-success-tips.php
• Widzinski,S. Importance Policies and Procedures – Documenting and Enforcing Them.
http://www.watkinsmeegan.com/expertise/resourcesandtools/Documents/Imp%20Policies%20
and%20Procedues.pdf