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The Enemy Within: Preventing Employee Conflicts of Interest at Investment Management Firms

Published by: TowerGroup

Published: Apr. 16, 2007 - 9 Pages


Table of Contents



TowerGroup Take-Aways

Report Coverage

Vision

Global Regulations: At the Heart of Personal Trading Oversight

Exhibit 1 Regional Examples of Regulation on Personal Trading by Employees of Securities Firms (2007)

Penalties Ripped from the Headlines

MiFID: More than Market Data and Best Execution

Issues Related to Employee Oversight and Certification

Exhibit 2 Preventing Conflicts of Interest: The Employee Oversight Process (2007)

Oversight of the Employee Certification Process

Employee Participation

Compliance Analysis

The Added Complexity of Personal Trading

Monitoring Households

Meeting Preclearance Requirements

Managing External Data

Managing Internal Data

Ensuring Global Privacy

Institutional Best Practices: Breaking the Habit of Paper

Coordinate attestations

Use third-party applications

Think internationally

Minimize the number of designated brokers

Considerations for Choosing Providers

Exhibit 3 Selection Questions for Institutions Choosing Personal Trading Surveillance Partners (2007)

Technology Spending Estimates

Exhibit 4 Global Spending on Third-Party Technology for Oversight of Conflict of Interest (2007P-12P)

Summary

Abstract

The combination of large sums of money, private information, and employees with access to that information creates an environment that is prone to inadvertent conflicts of interest and, more seriously, to a greater risk of internal fraud. Stakeholders demand high levels of internal control to guard against conflicts of interest, and asset managers have a fiduciary responsibility to meet these demands. This TowerGroup Research Note focuses the issues associated with preventing conflicts of interest and highlights best practices in improving employee involvement and corporate monitoring.

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