In Regulatory Wrap for the week to March 22, Rob Mason recounts what led to joint action penalties against a major U.S. investment bank for its lacking surveillance program.
In this Regulatory Wrap, we unpick the deficiencies that caused a U.S. investment bank to be fined $348 million by The Office of the Comptroller of the Currency and Federal Reserve Board, including venue coverage gaps and inadequate governance and oversight practices.
1. This situation was caused by gaps in venue coverage that contributed to missing trade data, as well as insufficient governance that the regulators described as “unsafe and unsound”
2. Surveillance teams can only monitor data that is being delivered to them, therefore front office employees who own upstream data sources need to provide them with relevant information
3. As a result of this penalty, firms in the industry are required to boost the comprehensiveness of their surveillance processes through using more thorough reconciliation to confirm the capture of complete data sets
4. Trading venues often use bilateral communications applications to discuss their trades, which is data that firms also need to make sure they account for
5. Firms should consider making use of open connector solutions, which can capture data from any communications source, to retain trade and order communications
This Regulatory Wrap is brought to you by Global Relay’s Director of Regulatory Intelligence, Rob Mason.
Leverage communications data and avoid hefty regulatory penalties by bolstering your surveillance procedures.
