May 16, 2013
The recent MoneyMate Data Management 2013 survey has some interesting insights into what is happening on the ground in 2013.
First up was a question on regulation - What regulations are impacting your firm’s operations the most in 2013?
Dodd-Frank topped the poll at 51%, which is high when you consider the respondents in the survey came from both sides of the Atlantic. Heretofore, many firms had indicated that Dodd-Frank was their chief concern – this was from a future impact perspective. The 2013 survey is indicating that this is now actually hitting home when it comes to day-to-day operations in 2013. If anything, I expect the impact of Dodd-Frank to grow and would expect next years survey to reflect that.
Another interesting finding in the survey is that 41% of the survey respondents have had an operational impact in 2013 with respect to preparing for FATCA, one can imagine what the impact will be once FATCA hits home fully. RDR was another notable hot spot with 30% of respondents highlighting it as something that was having a real impact in 2013. UCITS IV and Solvency II polled 36% and 21% respectively indicating European regulation is still a hot topic – even if EIOPA and the EU council have delayed the full deployment of the Solvency II framework. Interestingly, I have heard on the ground that RMORSA in the US is starting to surface as an issue for institutional managers with demands for more holding level transparency, including demands for look-through in multilevel portfolios e.g. fund-of-fund like structures. It will be interesting to see if RMORSA surfaces as a key trend in 2014 and it is something I will be keeping an eye on as 2013 rolls on.
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asset management, Data management, Dodd Frank, FATCA, RDR, Regulation, RMORSA, Solvency II, UCITS | Tagged: asset management, data management, Dodd-Frank, FATCA, funds, MoneyMate, RDR, Solvency II, survey, UCITS IV |
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Posted by Ronan Brennan
August 13, 2012
Regulation is a really key topic of conversation within the investment fund industry, and not without good reason!
On a recent webcast I did on the impact of regulation on data management strategies in asset management I explored the reasons why the global regulatory community have received an enormous level of flak since the 2007/2008 market implosion.
Clearly, the charge levelled at the regulators is that they failed to maintain a stable market – by not having a clear view of the systemic and systematic market risks that were at play.
The result is that we are entering a period of unprecedented demand for oversight and transparency – with one of the key challenges being adoption and migration to operating models that can keep up with the rapid change of the industry landscape – without leaving behind a legacy of manual error prone processes and key knowledge data sets that are poorly maintained.
So it is not without reason that the media and investment community alike are keenly interested in the regulatory backlash that we are witnessing. Regulation was always a driver within the industry, but more recently its prominence has increased because the fines are getting bigger, and the reputational damage is all the greater, due to the increased coverage in the media.
Recent news articles on Ignites are indicating the level of frustration with regulation is growing e.g. today we say the headline “KIIDS an unhelpful distraction“, last week we saw “UCITS IV, V, VI…stop now, says the market“
Over the coming days and weeks and I will explore this theme in-depth and publish some of the survey results from the webcast…
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Data Governance, Data management, Data Quality, KIID, Regulation, UCITS | Tagged: data management, KID, KIID, manual process, Regulation, UCITS, UCITS IV, UCITS V, UCITS VI, webcast |
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Posted by Ronan Brennan
August 10, 2012
For those of you who missed the recent webcast on regulation and its impact on data management strategies in the investment fund world, it is available for playback here…
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Data management, Data Quality, Dodd Frank, Event, FATCA, KIID, RDR, Regulation, RFP, RFP, Survey, UCITS, Volcker Rule | Tagged: accuracy, asset management, automation, consistency, control, data governance, data management, Data Quality, fact sheet, fund, investment management, investment product master, Key Information Document, KID, KIID, MiFID, MoneyMate, oversight, Regulation, regulator, transparency, UCITS IV |
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Posted by Ronan Brennan
July 18, 2012
I am hosting a webcast on “The Impact of Upcoming Regulation on Data Management” on Wednesday 25th July 2012, 3pm BST, 10am EST.
Regulation is a key challenge in the industry and in an unprecedented age of openness and transparency continues to be the no. 1 driver for asset managers investing in data and reporting initiatives. Companies want to mitigate the risk of inaccurate information being in the public domain and many are embarking on data management projects – which will save time, reduce errors and automate processes. The key themes we see center on capability to deliver a systematic, repeatable and auditable data publication process for client-facing data.
This webcast will be presented by myself, and will focus on how upcoming regulations will impact the industry and how asset managers need to prepare to ensure they stay ahead in a highly competitive market. Specific topics to be covered include: the latest version of AIFMD, the final throes of the Retail Distribution Review, the latest on KIID for PRIPS, UCITS V, how being important or “SIFI” is no longer so desirable, Volcker, FATCA and last but certainly not least Pillar III of Solvency II.
Finally, I will touch on what is around the corner and run through some recommendations with respect to preparing for the swathe of upcoming regulatory change.
To register for this webcast please click here.
I look forward to welcoming you online on July 25th.
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Data Governance, Data management, Data Quality, distribution, Dodd Frank, Event, FATCA, FINRA, KIID, product master, RDR, Regulation, UCITS, Volcker Rule | Tagged: accuracy, AIFM, AIFMD, asset management, asset manager, automation, back-office, consistency, control, data governance, data management, Data Quality, FATCA, investment product master, Key Information Document, KID, KIID, MiFID, oversight, RDR, Regulation, regulator, Solvency II, transparency, UCITS IV, UCITS V, Volcker Rule |
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Posted by Ronan Brennan
May 23, 2011
Following my last couple of blogs on the results of our survey around data management and regulation, I said I would post some information about the various regulations in each region and how they were likely to impact..
In North America, the regulators have always been to a large extent more rules than principles-based – this is not going to change – and – in the future we can in fact expect even more rules – not less.
The US alternatives space has seen many changes, particularly around registration, where many hedge fund managers now required to register with the SEC would previously have been exempt – this is causing many European hedge fund operators to consider their long-term strategy in the US. The implication of registration is that full books have to be maintained. Each firm must retain all data, and be able to produce records for SEC inspection. SEC examination is a particularly onerous process – with site visits, extensive questionnaires and vast demands for data.
The movement of the Dodd-Frank bill through the senate in summer 2010 ushered in a new era of regulation in the US, and we expect to see major changes to issues such as corporate governance, executive compensation and levels of disclosure and transparency. What we do not know yet is how the bill will directly impact the many rules we expect to see the SEC deliver, but we do know that the bill will allow the regulators to wield significant power and to determine the level of impact it will have on the market.
With the establishment of the Financial Stability Oversight Council and the Office of Financial Research, there is likely to be a more active approach to the management of market risk. This will manifest itself in increased reporting by asset management firms and funds on areas such as financial accounts, performance data, concentrations of risk and exposures to third parties. Increased demands for disclosure and transparency, including filing of full portfolios could also be seen, and there may also be demands for SEC mandated slices and views of the portfolio breakdown. Recent changes by the SEC to Money Market funds with the updates to 2a-7 are perhaps the clearest insight we have as to what to expect for the broader investment fund market – based on what we see in 2a-7 we might expect to see more rules on post trade compliance, public information filing and risk exposures.
Meanwhile, FINRA will be continuing to focus on maintaining market integrity, protecting investors and implementing key strands of the Consumer Protection Act within the Dodd-Frank reforms.
In Canada, a large segment of the industry is focussed on the new ‘Point of Sale’ fund fact documents which must be presented to investors prior to writing any investment from as early as July of this year.
Europe
European regulators are moving toward the North American model of regulation. So what was mostly regulation by principle will become regulation by rule. Tensions and strains within the EU came to the fore with French led demands for a move away from ‘light touch’ to ‘heavy touch’ winning out. Ironically though, the UK regulatory environment is probably the most rules-based of the current batch – I think it will become even more rules oriented , especially now that the FSA comes under the remit of the Bank of England.
Most discussion in the City these days though is about RDR and how the removal of commission incentives is re-shaping the sales/advice arena , with many Asset Managers now actively looking at IFA businesses and other distribution channels to give them access to the market.
On the cross-border front, the big news is the UCITS IV directive, and from a data management perspective the key discussion point is the KIID – or Key Investor Information Document. The KIID much like the CSA’s Fund Facts, is a simple 2-page document that should be delivered to the investor prior to investment. With KIID I see some serious data management challenges, in particular with the scale of the narrative data management, while the quant data should be more straightforward to deal with. To complement the rollout of the KIID initiative, Germany has passed legislation mandating the delivery of ‘product information sheets’ for investment products which are not covered by UCITS IV.
On the offshore side of things, we are already seeing change in Luxembourg and Ireland – in particular Ireland where we have seen the arrival of Matthew Elderfield, a former FSA department head.
The rise of the ‘Newcit’ – ostensibly a hedge fund in UCITS clothing – is creating a lot of regulatory discussion – while welcoming the on-shoring of some hedge funds, it is thought that many of the ESMA regulators hope that hedge funds will migrate towards the Alternative Investment Fund Managers Directive.
That’s a quick summary of the regulations I think will impact reporting and therefore might cause data management issues. We’re still seeing regulation as the major hot topic at industry conferences – everyone is talking about it and trying to get prepared for change.
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Data management, Data Quality, Dodd Frank, FINRA, KIID, RDR, Regulation, UCITS | Tagged: asset management, data governance, data management, Data Quality, FINRA, Key Information Document, KID, KIID, Regulation, regulator, SEC, UCITS IV |
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Posted by Ronan Brennan
May 10, 2011
This piece is a follow-up to my most recent blog posting on the results of our recent “data management and regulation” survey. I think the survey gave us a good chance to get a snapshot of what people are concerned about in terms of upcoming regulation and how it will impact their business processes.
The last posting was getting very long so I only posted some of the results. I finished up talking about the regulations that people were most concerned about in North America. The third question in our survey concerned European regulation and the topical issues there.
The question was: “in Europe, which of the following regulatory discussions concerns your organization most: RDR in the UK, UCITS IV & KIID for cross border funds, AIFM for hedge funds, the rise of Newcits, the upcoming UCITS V directive or the changeover from CESR to ESMA?”

Not surprisingly nearly two-thirds of all respondents indicated the big discussion point in their firm was UCITS IV and KIID – if anything the surprise is that it did not have a higher response. Maybe this is because many firms have focussed so heavily on preparation that they are very confident they are well placed to deal with the upcoming requirements that UCITS IV brings as well as the ability and readiness to initiate publication of KIID documents.
Nearly 30% of respondents indicated the AIFM directive, and an additional 17% indicated Newcits were items of discussion and concern in their firm – a clear indication that alternative strategies and the hedge fund industry are key industry focus points in the years ahead.
Somewhat surprising though is the fact that UCITS V is already a discussion point for 17% of respondents – the belief here is that the depositary structures that facilitated Madoff and manager remuneration are going to be addressed – these topics will ensure this is a hot topic of conversation for years to come.
Finally 17% of respondents indicated Solvency II was a key discussion point – this will become a key topic of conversation for any asset manager that has mandates emanating from the Life and Pension sectors – the demands on risk control, asset liability, ability to be transparent and report accordingly are all hot topics in the Sol 2 world.
Next up was the question: “How prepared is your organization for dealing with upcoming changes in regulation - are you totally prepared, somewhat prepared or not at all prepared?”

Thankfully the vast majority of respondents are at least somewhat prepared, but surprisingly only 15% or so indicated they believed their firms were totally prepared.
So it seems like the adage – a lot done, but more to do – seems prevalent here. Most firms are aware of what needs to be done, they have plans in place, but in some cases these plans have not been fully executed.
More reassuringly, we see that only 3% of respondents indicated that their firm is not prepared at all for the changes in regulation that are coming down the tracks. Overall, the responses to this question indicate that firms are struggling to prepare for the enforcement of regulatory reform, particularly in terms of their product data.
The next question in the survey was: “Do you think that new regulatory reporting requirements will change your organization’s attitude towards data management?”
The responses to this question were most interesting…… 
Nearly one-quarter (23%) of all respondents indicated that recent regulatory changes will force their firm to totally change their processes for getting their product data into the market, while only 12% of the respondents indicated that their existing processes were fully supportable, automated and left a full statement of record to facilitate audit.
The greatest number of respondents (56%) indicated that their firms only needed to make some amendments to the existing processes in their firm, for the management of product data.
The response to this question aligns with previous responses – where it would appear that in most cases firms know what they need to do, but have not fully executed their plans.
Overall, the responses to the survey questions indicate that firms are struggling to prepare for the enforcement of regulatory reform, particularly in terms of their product data.
The final question in the survey was: “What are the biggest challenges in getting your product data to market – are they manual processes, timeliness, cost, accuracy or something else?”

The big shock here is that just over half (53%) of respondents indicated that the biggest obstacle to getting their product data to market is manual processes, with a similar number indicating that timeliness was an impediment. It is not surprising that 40% indicated cost was a problem – this most likely results from having issues with manual processes.
Of most concern though should be the more than one-third of respondents that indicated accuracy was a problem for them. This is worrying indeed when you consider the considerable focus that has been placed on data management in recent years and the vast amount of IT dollars that have been spent trying to address the problem.
Finally the 6% other – commented that ability to maintain a statement of record or auditable trail of ownership was their greatest challenge – which is interesting – the inference we derive here is that these firms have automated processes and reasonable levels of accuracy, but proving this and showing a demonstrable audit trail to auditors and regulators alike is a particular concern.
So that’s it on our survey results – I thought they were worth sharing with a wider audience and it might give you an insight into how people are preparing for upcoming regulation.
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Data management, Data Quality, Dodd Frank, KIID, Regulation, Survey | Tagged: accuracy, asset management, back-office, chief data officer, consistency, data governance, data management, Data Quality, FINRA, investment management, Key Information Document, KID, Regulation, regulator, timeliness, transparency, UCITS IV |
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Posted by Ronan Brennan
January 14, 2011
Warning: this is a rant….
I am totally fed up with getting emails from vendors claiming to have the “be-all-and-end-all” solution for supporting the UCITS IV Key Investor Information Document – unfortunately all of the solutions I have seen are focusing on a narrow aspect of the problem space…
I see the following problem spaces being targeted: distribution, production, comparison, work-flow, narrative management, and data management / data quality management.
Some vendors see KIID as a distribution problem – which let’s agree is part of the issue. Asset management companies will have a challenge in getting their KIID documentation out to market, but this will be no different to the problems they have today with getting their other compliance (e.g. simplified prospectus) and marketing documents (fact sheets) to market. The emergence of global and local document stores from e.g. Morningstar, FundsLibrary and FundInfo will facilitate and make this process more straightforward. The platforms and open-architecture distribution houses will also have problems sourcing the latest KIID, again though the document store vendors will solve this problem.
Some vendors see the issue purely as a document production exercise – they do not care where the data is coming from, what quality it is, nor do they have any interest in the data – other than to collate it all together into a nice glossy document. They seem to have lost sight of the fact that this is a legal document, albeit it in the guise of a marketing document that should be understandable by the average person on the street. KIID is not a marketing document – the gloss factor of the document is a very low priority for asset managers who are concerned about KIID - their issue is getting the document to market with consistent, accurate, timely data – with narrative that is clear and understandable. Some of these vendors are even offering to create the KIID directly from the simplified prospectus, even though the KIID guidelines very clearly and without any ambiguity state that the content for the document should not be extracted from the prospectus documents.
Other vendors see the problem space as one of workflow – so they have spotted that this document is not your average marketing output and does have some requirement for approval across many departments. I think these vendors are starting to touch on the aspects of KIID that are of true concern to compliance and marketing officers who are actively engaged in KIID projects today. You see the document is definitely a legal document and so compliance want to have a defined role in the document sign-off, but marketing also have a role to play in ensuring the document is drafted in language that can be understood by the average investor of the fund – marketing may even be the main sponsor of the project since the document is ultimately required at point-of-sale.
My own discussions lead me to the conclusion that what is worrying asset managers most is how they will manage the narrative texts within the document, ensuring that compliance, marketing and the investment manager all get to review and comment before publication. But implementing a review cycle with multiple interested parties for what could be hundreds of documents for a medium-sized asset manager and potentially thousands for a larger manager is a daunting task. When you add to this the task of managing the quality of the data flowing into the document production process you have a problem of truly epic scale.
To have a scalable and efficient KIID process, you do need all the wheels and cogs in your machine working in tandem – so do not lose sight of the broader problem spaces – ensure your project has in-scope: distribution, production, comparability, work-flow, narrative management and data quality management.
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Data Quality, Regulation, Technology | Tagged: accuracy, asset management, asset manager, automation, consistency, control, fund, investment management, key investor information document, KID, KIID, simplified prospectus, UCITS IV |
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Posted by Ronan Brennan
October 11, 2010
There are lots of people with differing views on what exactly MDM (Master Data Management) means. The philosophical answer is that it means whatever you want it to mean – more importantly your own experiences and personal environment will largely dictate what it means to you.
Read the rest of this entry »
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Data Quality, Technology | Tagged: investment product master, Data Quality, ETL, consistency, accuracy, timeliness, tearsheet, fund, data governance, UCITS IV, KID, SMA, data quality management, factsheet, simplified prospectus, summary prospectus, CSA, fund facts, governance, stewardship, MDM, Master Data Management, collective investments, pooled investments, mutual fund, Account, fee, charges, KII, KIID, POS, annual reports, system of entry, statement of record |
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Posted by Ronan Brennan
April 27, 2010
I see a few interesting developments on the horizon with respect to data and the various financial regulation bodies.
I have kept my musings deliberately brief – if anyone is looking for more in depth commentary let me know and I will do a follow-up post on that topic…
Read the rest of this entry »
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Data Quality, Regulation | Tagged: 12b-1, 2(a)-7, 40 act, accuracy, asset management, breaking the buck, canada, CESR, client reporting, compliance, CSA, data, Data Quality, fee reform, financial regulation, FINRA, fund facts, fund rules, ific, Ignites, investment companies act 1940, Key Information Document, KID, marketing, Mary Schapiro, middle-office, MiFID, money market, Morgan Keenen, point of sale, RDR, Regulation, regulator, reporting, retail distribution review, SEC, transparency, UCITS, UCITS III, UCITS IV, UK, US |
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Posted by Ronan Brennan
April 1, 2010
As promised in the previous post, here is a synopsis of the second panel I sat on at TSAM recently.
The discussion centered on the changing shape of regulatory requirements and the implications for the buy-side – with specific emphasis on the following points;
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Data Quality, Event, Regulation, Technology | Tagged: accuracy, asset management, audit trail, automated, automation, buy-side, CESR, client reporting, consistency, control, Data Quality, EMD Council, FINRA, fund, funds, Geoff Fensome, institutional accounts, investment product master, investment products, Investment Solutions Consultants LLP, ISC, JWG Group, Key Information Document, KID, KYC, MiFID, Mike Atkin, PJ Di Giammarino, RDR, Regulation, retail funds, SEC, SMA, systematic, timeliness, transparency, TSAM, UCITS III, UCITS IV |
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Posted by Ronan Brennan