Code of Ethics and Personal Securities Trading Module
An automated supervisory solution to personal securities trading gifts and entertainment and political contributions..
Creating a Code of Ethics program that meets regulatory requirements while also seeking to provide supervisory oversight of personal securities trading, gifts and entertainment and political contributions is a time consuming challenge. Lack of a systematic, integrated approach can expose your firm to regulatory deficiencies and possible insider trading violations.
The NRS Solution
The NRS ComplianceGuardian Code of Ethics module includes automatic oversight of personal securities trading monitoring, gifts and entertainment and political contributions tracking, required anual holdings and quarterly transaction reporting and attestations are built into the system. Your firm specific rules are integrated into the workflows to assist reviewers in approving or denying activities. In addition, this module provides a method for users to report Code of Ethics violations so that firms can prove to regulators that there is a way for employees to report when necessary and as required by the rule.
The NRS Code of Ethics Module Provides:
Code of Ethics
This module includes a customizable code of ethics document which is easily accessible online for access persons. Completing a set of questions will automatically set up the firm's trading, gifts and entertainment and political contribution rules. Integrated is an attestation which can be archived, as required by regulations.
Automated Trade Preclearance and Exceptions
This module will automatically process preclearance requests against prior trades and your Code of Ethics trading rules. Each day, the actual trading data will be processed and potential trading rule violations will be sent as exceptions for further review and resolution.
Automated Reporting for Annual Holdings, Quarterly Transaction and Initial Holdings
Regulatory requirements require firms to review annual holdings and quarterly transaction reports. In addition, newly designated access persons must file an initial holdings report. This module provides access to the reports as well as the ability to save the reports in different formats for archiving purposes.
Attestations and Automated Archiving
This module assists in creating the required reports and automatically sending email reminders to users to attest to those reports. Attestations, with transaction or holdings information, is archived and saved as pdf files for firms.
Create and Manage Multiple Restricted Lists Simultaneously
Manage multiple restricted lists based on your firm’s different trading groups or other supervisory structures. Restricted lists can vary within firms and this module allows multiple users within a firm to create different restrictions. Those restrictions can then be applied to individuals or defined groups within the firm.
Integrated Code of Ethics Trading Rules
This Personal Securities Trading Module easily creates a Code of Ethics that integrates your trading rules so that access persons not only attest to this Code but also have their trade requests reviewed by the system based on these rules. Trading rules are created using the profile tool which can be changed any time your firm changes its rules.
Manage Heightened Supervision Individuals Easily
Every firm has its own set of requirements regarding individuals that challenge the firm’s trading rules. Or new employees may need more oversight for an initial period of time. Manually reviewing these trades regardless of whether or not a rule has been violated is as simple as checking a box for that person.
Manage Gifts and Entertainment Requests
This module allows users to enter information about gifts and entertainment for pre-approval or to report gifts received to the firm. With the provided aggregated information, firms can approve or deny the requests.
Political Contributions Requests
Firms need a way to understand contributions made to political parties as required. This module allows firms to maintain the required information as well as approve or deny contribution requests.