“ I would say that the biggest issue that we
find is that so many firms comply with
the letter of the personal trading rule, in
regards of getting reports of personal
trading and trying to get those reports in
on a timely basis, but where they fall
down is they don’t do anything with the
reports...We feel that’s just a huge gap in
the firm’s compliance program.”
— Gene Gohlke
Associate Director of the SEC’s office of
Compliance inspections and examinations
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ACA’s Compliance Tracking System™ (“CTS”) is a comprehensive, multi-functional, web-based system that is designed to assist investment advisers with a variety of compliance and regulatory requirements — including personal account trading compliance.
If you are looking to cut costs and increase efficiencies in your compliance program, the implementation of the CTS can be a cost-effective solution to free up resources that are currently dedicated to the personal trading reporting and review process.
CTS provides a fully customizable and user-friendly environment that includes the following features:
ACA has arranged for five top broker/dealers (Charles Schwab, E*Trade, Merrill Lynch, Smith Barney and TD Ameritrade) to directly feed brokerage account information into CTS. ACA is welcome to onboarding additional broker/dealers at the request of users. ACA’s dedication to superior client service will facilitate the process of obtaining the direct electronic broker feeds and we will work with system users during every step of the process.
ACA’s regulatory compliance team, comprised of former SEC, FINRA, NYSE and state regulators, draws on a diverse background of experience to provide assistance with personal securities transaction reviews, conflict and exception reviews, and regulatory compliance questions.
The file import tool allows users to import custodial account information into CTS to build various required reports and allows the system administrator to manage the restricted/watch lists in an efficient manner.
Customize and manage your firm’s preclearance authorization process for personal account trading, the opening and closing of brokerage accounts, gifts and entertainment compliance, outside business activity requests or any other regulatory or firm approvals to help ensure comprehensive, documented compliance with applicable regulations and mandates.
Record and track employees’ and access persons’ personal account trading through multiple reporting avenues including: electronic broker/dealer feeds, file import tool, manual entry, and ACA data entry.
Configure pre-defined rules and restrictions to identify and report any activities that may violate the firm’s internal policies and/or securities laws or may draw attention in future SEC examinations. Generate a number of standard and custom reports with granular filtering options which can be exported to MS-Excel or a printer friendly format.
The tools allow the system administrator to manage messages to end users, manage user accounts, access all user accounts, review all employee form submissions and manage broker/dealer feeds.
ACA provides a managed Hosted Solution and a managed Dedicated Hosted Solution which are hosted and maintained at Equinix, one of the leading global hosting providers in the financial services industry.
At ACA, we ensure your data is secure. ACA’s privately managed servers are protected by the latest firewalls, VPN routers, IDS/IPS systems and computer/internet security updates.