Software developed by Rule Financial for a Tier 1 bank is enabling it to meet FSA requirements on market abuse and streamline its personal account dealing 

Banks today need to avoid reputational risk and maintain client confidence by minimising the likelihood of conflicts of interest. They also have obligations under various regulatory systems, including MiFID, to track trends, authorisations and prohibitions for personal account dealing.

As well as responsibilities to both clients and regulators, banks need to make sure that their employees’ personal account dealing meets stringent privacy considerations and that no unauthorised person has access to data on either pricing or trading. The objective of the project was to build a system which fulfillied all these requirements, providing functionality for employees, business line pre-approval and compliance pre-approval together with management reporting. The system also had to be extensible so it could be rolled out globally.

With full functionality operative in the UK, the compliance system will shortly be introduced in the Asia Pacific regions followed by staged rollouts across the rest of the world.

The system includes the following features:

• Ability to approve or decline broker account requests
• Ability to approve or decline trade requests based on a global policy
• Automated checks of restricted list and research restrictions
• Automated checks of sensitive products
• Alerts to compliance operatives
• Multiple workflows for specific employees and/or departments
• A  fully configurable security module to ensure data privacy by role, region and permission
• Automated email notifications
• The provision of information enabling compliance staff to enhance their decision making processes and to check stop and watch lists
• Reconciling trade requests with copy contract notes
• Functionality to breach trades

Rule Financial provided project management, business analysis, development capability and test management. We started by facilitating workshops for the Global Heads of Compliance to initiate the requirements-gathering process. We then refined the requirements as use cases and used Scrum methodology to build the software in two-week sprints. The advantage of this methodology was that the client saw the software grow iteratively and they were able to make changes and refinements before it was “set in stone”.

The system also provides an extremely flexible administration module enabling the bank to configure frequently changed aspects through the front end rather than being reliant on database and code fixes.

                                                    Sylvia Shepperson