USE OF TECHNOLOGY
Technology, if correctly utilized, can create significant efficiencies for the majority of compliance departments. SEC³ has partnered with Orion Compliance (formerly BasisCode Compliance), an unaffiliated provider of a suite of robust compliance software solutions that are used by some of the world’s leading financial services, consulting, legal, accounting, fund administrators and broker-dealer organizations. As an original member of BasisCode’s Steering Committee, SEC³ has developed a strong working relationship with BasisCode (and now with Orion Compliance) and has been able to help drive the creation of new and enhanced features. SEC³ employees a unique methodology to capture the strengths of Orion Compliance, which are tightly integrated with a client’s written policy and procedures to provide a holistic, transparent view of their compliance program in real-time, ultimately reducing SEC exam risk. Orion Compliance’s core modules include:
Exam Readiness
Exam readiness is without question, the greatest benefit of Orion Compliance if utilized correctly. Through SEC³’s unique processes including the cataloging of data, clients will be able to avert an otherwise inevitable fire drill and, in a matter of hours or a few days, complete a routine request list and monitor its regulator exam readiness.
Annual Review Documentation
An automated and customized solution designed around an adviser’s available resources to evidence their required 206(4)-7 Annual Review that systematically and quickly compiles and catalogues the supporting work allowing the adviser to document their effort to assess the adequacy of the policies and procedures established and the effectiveness of their implementation.
Risk Assessment
Effectively document the adviser’s efforts to identify conflicts and other compliance factors creating risk exposure for the firm and its clients.
Personal Trading - Automation
Establish customized, pre-authorization workflow including comparing trade requests to one or more restricted/watch lists. Automatically capture the personal trading of all Access Persons and quickly perform customized trade reviews, which incorporate various risk metrics depending on the adviser’s policies.
Timely Monitoring of Suspicious or Abnormal Trading
Establish proactive and timely monitoring of trading by access persons and the firm to detect suspicious or abnormal trading that may violate the adviser’s policies including the misuse of material non-public information.
Third-Party Service Provider Due Diligence
Automate the delivery, capture and review of initial and ongoing third-party service provider due diligence.
Marketing Review
Establish automated workflow to submit, review, and approve marketing material. Each piece of submitted material is recorded with time-stamps throughout the review process including copies of the media assets throughout the review process.
Gifts and Entertainment
Establish automated workflow to submit, review, and approve any gifts and entertainment. Tailor restrictions and limits based on the adviser’s Code of Ethics. Each submission is maintained and documented and can easily be downloaded as part of the adviser’s Gift Log.
Whisleblower
Establish automated workflow to submit, review, and document any whistleblower complaints. Establish proper protocols on potential recipients and adviser’s procedures on how complaints are handled. All whistleblower complaint submissions can be tracked and documented based on adviser’s books and records requirements.
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Orion Compliance streamlines the management of personal trading including pre-clearance and post clearance, trade request analysis and employee-managed or direct feed brokerage options. Orion Compliance also offers a unique and proactive approach to monitoring insider trading that enables users to detect suspicious or abnormal trading that may violate their policies including the misuse of material non-public information.
Exam readiness is probably the greatest benefit of Orion Compliance if utilized correctly. Through SEC3’s unique processes, SEC, NFA and FINRA registrants will be able, in a matter of hours or a few days, to complete a routine request list and monitor its SEC exam readiness.
