22c-2 Demands Resources...Do You Have The Right Ones To Deal With It?
Complying with SEC Rule 22c-2 is more than accessing data. Once you’ve acquired the data, you must
identify market timers, communicate exceptions to your intermediaries and create compliance records
for future audit needs. That’s where Boston Financial can help. Our Full Service Solution offers a suite
of services to help you address this complex regulation, including:
Maintain Intermediary Surveillance Schedules
Working with you and incorporating your risk assessments and overall compliance plans, Boston Financial will establish a surveillance schedule for each Intermediary detailing the data to be requested and on what frequency. This schedule also includes information about how the data will be received and in what format.
Data Management Monitoring
In addition to requesting data from your Intermediaries, our Desktop tool provides the current status of each request made to ensure your intermediaries respond within the agreed upon timeframe.
Customized Reporting Solutions for Market Timing Analysis
As part of Boston Financial's reporting package, you not only are eligible to receive our
standard reports available through DST's TA2000TM Omnibus Transparency solution, but we
can support your requirements for customized reporting through the use of Power SelectTM 1.
Daily Exception Analysis of Market Timing Policies
Once you have the data from your Intermediaries, you'll need an effective way to analyze the data to identify potential market timers or abusive traders. We incorporated DST's Short Term Trader and Excessive Trader engines to review the Intermediary data in exactly the same way the non-omnibus account data is analyzed to assess short term trading fees, or to identify abusive trading patterns. A dedicated Trade Surveillance Group reviews potential issues daily.
Communication and Resolution of Market Timing Exceptions
Our operating model is flexible. You have a choice regarding your level of involvement
with Intermediary communication and the manner in which you would like to approach market
timing exceptions. Because of the flexibility of DST's AWDTM work-flow system, source
documents and activity to resolve exceptions are documented and easily shared with you either during the process, when completed or on a periodic basis.
Intermediary and Trade Compliance
Because we use the same tools to analyze the Intermediary data as we do to analyze the rest of the activity on your register, you are assured that your fund trading and market timing restrictions are consistently applied across accounts on the fund register.
Management Reporting
On a monthly basis, we will summarize the activity associated with Rule 22c-2 compliance and report this to you as a part of the regular monthly reporting from your Relationship Management Team.
Integrated Technology Solutions to Support Compliance with 22c-2
With the Boston Financial Full Service Solution, all of the technology that
supports your compliance with Rule 22c-2 comes from DST. Furthermore, the solution is
fully integrated with TA2000TM and with AWDTM, which provides a start-to-finish process
requiring little involvement from you, along with a comprehensive audit trail for future inquiries.
1 Power Select is a tool used by Boston Financial for customized reporting.
For more information about the Boston Financial Full Service Solution,
please call Craig Hill at 816.843.8894.
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