White paper. Regulatory Reporting Reforms for Investment Management: `A Case for a Strategic Regulatory Reporting Platform

Similar documents
The SEC s Proposed Reporting and Disclosure Changes: What Investment Companies and Advisers Should Know

Significant SEC Rulemaking to Address Liquidity of Mutual Fund Portfolios

DECEMBER 8, 2010 FINANCIAL MARKETS UPDATE. SEC Proposes Rules Exempting Certain Private Fund Advisers from Investment Adviser Registration.

Financial Services Investment Companies (Topic 946)

Closed-End Funds. A closed-end fund is a type of investment company. whose shares are listed on a stock exchange

Federated High Income Bond Fund II

IN FOCUS. A practical guide for alternative investment managers on creating registered open-end mutual funds

SUMMARY PROSPECTUS SDIT Short-Duration Government Fund (TCSGX) Class A

SUPPLEMENT Davy Strategic Global Equity Fund

UBS RMA Money Market Portfolio U.S. Government Portfolio Tax-Free Fund California Municipal Money Fund New York Municipal Money Fund

Understanding mutual fund share classes, fees and certain risk considerations

Federated Mid-Cap Index Fund

Cash Management Group Solvency II and Money Market Funds

Board Oversight of Exchange-Traded Funds

SEC Proposes Changes to Open-End Funds Related to Management of Liquidity Risk

BMO Mutual Funds 2015

Diversification. Mutual funds must declare themselves to be diversified or nondiversified.

Exchange-Traded Fund RiverFront Dynamic Unconstrained Income ETF RiverFront Dynamic Core Income ETF

ABF PAN ASIA BOND INDEX FUND An ETF listed on the Stock Exchange of Hong Kong

GOLDMAN SACHS VARIABLE INSURANCE TRUST

Financial Stability Oversight Council. Staff Guidance. Methodologies Relating to Stage 1 Thresholds. June 8, 2015

Federated Max-Cap Index Fund

Chapter 2 Characteristics of Investment Companies

Federated Total Return Government Bond Fund

Improved Efficiency and Significant Cost Savings through a Flexible Managed Services Model

Gain superior agility and efficiencies with enterprise origination solution. Finacle Origination

Seix Total Return Bond Fund

ADVISORY Private Funds

Important Information about Closed-End Funds and Unit Investment Trusts

F R E Q U E N T L Y A S K E D Q U E S T I O N S A B O U T C L O S E D - E N D F U N D S

Chapter 1 THE MONEY MARKET

CONDITIONS FOR ULTIMATE HOLDING COMPANIES OF CERTAIN BROKERS OR DEALERS SEA Rule 15c3-1g (Appendix G)

European Commission Releases Proposal for Regulation of Money Market Funds 4 September 2013

F R E Q U E N T L Y A S K E D Q U E S T I O N S A B O U T C L O S E D - E N D F U N D S

Creating Business Value with Mature QA Practices

NORTH AMERICAN HIGH YIELD BOND FUND (PUTNAM)

BMO Floating Rate High Yield ETF (ZFH)

APX GROUP HOLDINGS, INC. REPORTS FIRST QUARTER 2014 FINANCIAL RESULTS

LVIP Dimensional Non-U.S. Equity RPM Fund. Summary Prospectus April 30, 2013

RISK DISCLOSURE STATEMENT

ALLOCATION STRATEGIES A, C, & I SHARES PROSPECTUS August 1, 2015

View Point. Image Area. Insurance Modernization New Demands, New Approaches. - Jeffrey Kupper, Lalit Kashyap, Siva Nandiwada, Srikanth Srinivasan

TIMIA CAPITAL CORP. (the Company ) (FORMERLY GREENANGEL ENERGY CORP.) MANAGEMENT DISCUSSION AND ANALYSIS in Form F1 ( MD&A )

GOLDMAN SACHS REPORTS SECOND QUARTER EARNINGS PER COMMON SHARE OF $1.98; LITIGATION PROVISIONS REDUCED EARNINGS PER COMMON SHARE BY $2.

Income dividend distributions and distribution yields

Fair Value Measurements and Disclosures (Topic 820)

John Hancock Government Income Fund. Quarterly Portfolio Holdings

Basel Committee on Banking Supervision

Chief Executive Officers of All National Banks, Deputy Comptrollers (District) and All Examining Personnel

J.P. Morgan Securities LLC CFTC Supplemental Disclosures

Exchange Traded Funds: State of the Market, Regulation and Current Concerns

UBS RMA Money Market Portfolio U.S. Government Portfolio Tax-Free Fund California Municipal Money Fund New York Municipal Money Fund

Debt securities statistics: the Bank of Thailand s experience 1

Addressing the Liquidity Challenge Corporate Bond New Issue Standardization

Dodd-Frank Act: Impact on Business and IT

Federated Quality Bond Fund II

STANDARD LIFE EUROPEAN PRIVATE EQUITY TRUST PLC

Regulatory Practice Letter September 2013 RPL 13-18

Federated U.S. Government Securities Fund: 1-3 Years

Evergreen INSTITUTIONAL MONEY MARKET FUNDS. Prospectus July 1, 2009

Dealer Member Rules that will become effective in the coming months include:

FS Regulatory Brief SEC Proposes Amendments to Broker- Dealer Financial Reporting Rule

Managed Account Series BlackRock U.S. Mortgage Portfolio (the Fund )

(expenses that you pay each year as a percentage of the value of your investment)

Federated Municipal Obligations Fund

Lecture Notes on MONEY, BANKING, AND FINANCIAL MARKETS. Peter N. Ireland Department of Economics Boston College.

Understanding the 2013 Year-End Distributions Table

Financial Markets and Institutions Abridged 10 th Edition

GAO. MUTUAL FUND FEES Additional Disclosure Could Encourage Price Competition

LVIP Dimensional U.S. Equity RPM Fund. Summary Prospectus April 30, (formerly LVIP Dimensional U.S. Equity Fund) (Standard and Service Class)

MALTA TYPES OF COLLECTIVE INVESTMENT SCHEMES

Basel II, Pillar 3 Disclosure for Sun Life Financial Trust Inc.

Goldman Sachs Bank USA and Subsidiaries Consolidated Financial Statements As of and for the years ended December 31, 2012 and December 31, 2011

SUMMARY PROSPECTUS. BlackRock Funds SM. Service Shares BlackRock Science & Technology Opportunities Portfolio Service: BSTSX JANUARY 28, 2016

Moody s Analytics. RECOVERY RATE Peer Analysis Portfolio VALUE. Counterparty. EDF Through-the-Cycle EDF MODEL. Credibility DEFAULT RATES

Macquarie Significant Investor Visa Funds

Modernization of Investment Funds Final Amendments of Phase 2

Background Information on the Funds

The University of North Carolina at Greensboro Investment Fund, Incorporated (A Component Unit of The University of North Carolina at Greensboro)

SUMMARY PROSPECTUS. BlackRock Liquidity Funds Select Shares California Money Fund Select: BCBXX FEBRUARY 29, 2016

ETFs for private investors

DFA INVESTMENT DIMENSIONS GROUP INC.

The Goldman Sachs Group, Inc. and Goldman Sachs Bank USA Annual Dodd-Frank Act Stress Test Disclosure

Bond Fund of the TIAA-CREF Life Funds

Auditing Derivative Instruments, Hedging Activities, and Investments in Securities 1

Public Financial Disclosure A Guide to Reporting Selected Financial Instruments

SUMMARY PROSPECTUS SUPPLEMENT

FRONT STREET STRATEGIC YIELD FUND LTD.

MML SERIES INVESTMENT FUND

SUMMARY PROSPECTUS SIPT VP Conservative Strategy Fund (SVPTX) Class II

WHITE PAPER. OTC Derivatives From Reform to Reinvention Convert regulatory compliance into business transformation. Abstract

CLIENT RELATIONSHIP DISCLOSURE STATEMENT

CANACCORD GENUITY INVESTMENT FUNDS PLC. Supplement dated 11 November 2014 to the Prospectus dated 11 November 2014 CGWM SELECT INCOME FUND

Action: Notice of an application for an order pursuant to: (a) section 6(c) of the Investment

Streamlined Operations Through New Business Process Transformation

NATIONAL INSTRUMENT COMMODITY POOLS TABLE OF CONTENTS

Guidelines for competent authorities and UCITS management companies

Why Invest in a Non-Traded Business Development Company?

REED SMITH LLP INVESTMENT ADVISER NEWS QUARTERLY UPDATE

CHAPTER 16 INVESTMENT ENTITIES

Transcription:

White paper Regulatory Reporting Reforms for Investment Management: `A Case for a Strategic Regulatory Reporting Platform

Background and call for action The investment management industry has seen several key changes in the past few years characterized by an ever-increasing and rapid asset-base growth, new structures, and increasing complexity of the underlying portfolio. Some of the most notable trends are: The amount of assets held by US mutual funds, excluding money market mutual funds and exchange traded funds, is increasing rapidly. Assets grew from US$4.4 trillion in 2000 to US$15.8 trillion in 2015 Potentially less liquid mutual fund categories have grown substantially over the same period. For example, foreign bond and foreign equity funds have grown from around 11% of the total industry assets in 2000 to 19% in 2015 There are several other industry drivers for upcoming regulator driven changes in mutual funds industry: The long overdue modernization of the reporting requirements amidst great advances in the technological landscape for aggregation, analysis and reporting information Rapid adoption of Internet as a reliable channel for dissemination of information) for Investment Management firms to SEC An overarching debate on potential systemic risk posed by Investment Managers and need for greater transparency by Industry participants These factors have culminated into two recent landmark reforms proposals from SEC: Liquidity Risk Management Programs for Open Ended Funds Investment Company Reporting Modernization This paper examines the impact of the modernization of investment company reporting on the industry participants, and our recommended approach to address the same. As part of this proposal, SEC requires firms to significantly strengthen and update reporting and disclosure of their portfolio holdings. The highlights of this proposed rule are as follows: File a new monthly portfolio reporting form, Form N-PORT, that would provide portfolio-wide and position-level holdings data to the SEC on a monthly basis Enhanced and standardized disclosures in the financial statements File a new annual reporting form, Form N-CEN, that would provide certain census-type information to the SEC Satisfy transmission requirements by making reports accessible to shareholders on their website Infosys believes that these changes have a major impact on buy-side firms reporting processes, data, and infrastructure, and the time to act on these proposals is now.

What are the changes? Concurrent with the trends in industry, the investment management firms will have to contend with increasing the frequency, enhancing the usability, and improving the quality of the detailed disclosures of the holdings. The summary of changes to the forms and rules for registered investment companies is as follows: A new form, N-PORT, has been introduced that would mandate certain registered investment companies to report information about their portfolio holdings in a structured data format (XML) on a monthly basis A new form, N-CEN, has been introduced requiring registered investment companies to report certain census-type information to the SEC annually. The proposals would rescind current Form N-Q and Form N-SAR, respectively Changes to Regulation S-X, would require a registered investment company to include standardized, enhanced disclosure about its investments in derivatives in its financial statements as well as other disclosures related to liquidity and pricing of investments A new rule, 30e-3, allows registered investment companies to transmit periodic reports to shareholders on a website Form N-PORT In addition to providing holdings information, firms will have to disclose the following as part of the new Form N-PORT: Firms use of derivatives Risk metrics that measure an exposure to changes in interest rates, credit spreads, and asset prices Information about securities lending and repurchase agreements including the counterparties that the fund is exposed to Information about counterparties in over-the-counter (OTC) derivatives transactions Information on the liquidity risk profile of the holding market liquidity, pricing of portfolio investments, and fund flows Apart from some general information about the fund that includes name of the registrant, name of the series, Legal Entity Identifier (LEI) number of the registrant, and series, etc., the following table captures the key schedules that are part of Form N-PORT and the corresponding information that needs to be captured: Schedule Key information ask Assets and liabilities Total assets, liabilities, net assets, miscellaneous securities, assets invested in controlled foreign corporation (CFC) including underlying investments in a CFC Portfolio-level risk metrics Interest rate duration, spread duration, liquidity profile of the funds at a portfolio level (funds with >20% threshold for debt and/or derivatives exposure) Securities lending Counterparty information (LEI and aggregate value of all securities on loan) and positionlevel information, fees and revenues associated, and impact on investment performance Return information Monthly returns attributable to derivatives and other investments for each of the preceding three months Flow information Shares sold, repurchased, reinvested, and redeemed Schedule of portfolio investments Investment-wise details issuer data, amount, payoff profile, fair-value level, whether restricted security or illiquid asset, and counterparty details (in case of derivatives) Table 1: Overview of schedules This information needs to be provided monthly in standard XML format within 30 days after close of each month to the Commission, and quarterly to the public (monthly of each fund s fiscal quarter) within 60 days of the end of the fiscal quarter. Form N-CEN The information and form attachments for N-CEN would be similar to those currently required on Form N-SAR, including background information about the firm and its classification, as well as the identity of its principal underwriters and its officers and directors. The following are salient characteristics of the new form:

Proposed Form N-CEN would include a new item requiring reporting as to whether the firm relied on exemptions granted by the SEC during the reporting period Among other additional items required, the proposed Form N-CEN would include an item relating to whether an open-ended fund made any payments to shareholders or reprocessed shareholder accounts as a result of an NAV error Other information on Form N-CEN relates to: Information on classes of shares Information concerning investments in CFCs Additional information regarding their securities-lending activities, including whether the firm is authorized to engage in securitieslending transactions and whether it loaned securities during the reporting period Reporting on whether the firm relied on certain rules under the Investment Company Act Information regarding expense limitations Information on the RIC s service providers

Implications and benefits to market participants Investors / Shareholders Market regulator (SEC) Investment companies / service providers / administrators (custodians) Intermediaries (broker dealers / investment advisers) Greater transparency through disclosures into fund s exposures, particularly derivatives, miscellaneous securities, counterparties, and overall liquidity profile Flexibility and improved information accessibility via electronic / web delivery Enable improved analysis and monitoring of systemic risk and counterparty risk Establish further standardization and consistency of reporting information across fund industry, and enable peer analysis Promote industry standards like LEI, XML / XBRL reporting in the fund industry Increased regulatory burden, operational and technology change impact - manage a much larger data set and report more frequently Increased risk reporting Reduced burden of printing and mailing costs Additional information and analysis to aid fund investors decision-making Greater transparency of information regarding loan or borrowing of securities Table 2: Implications for market participants Expected challenges The proposed mandates include substantial changes in reporting for investment companies to the SEC. Some of the key execution challenges are: 1 2 3 Lack of data standards Unavailability of risk metrics Lack of data granularity of the information Availability of Legal Entity Identification (LEI) associated with each fund LEIs for the counterparties Fund and portfolio-level calculation of duration and spread associated with debt instruments Liquidity classification of the portfolio holdings Investment details of securities classified as miscellaneous Realized appreciation / depreciation associated with derivatives and other instruments on a monthly basis 4 5 6 Increased frequency of reporting and reduced reporting window Tight implementation timelines Limitations of the existing technology landscape The firms will likely struggle with requirement to file the monthly Form N-Port within 30 days of month close and the yearly Form N-CEN within 45 days of year close SEC expects firms to comply within 18 months (likely in early- to mid-2017) Multiple data sources and limited data reconciliation and aggregation capabilities Absence of a standard reporting solution compatible with regulatory reporting Manual processes for `record to report life cycle Table 3: Challenges

Recommended approach Infosys recommends utilizing its proprietary services suite AiKiDo anchored on industry-leading solutions to meet these regulatory reporting reforms. However, investment management firms will have to adhere to the following tenets before embarking on the road to implement changes proposed by SEC: Identify the impact on the business processes, data, and technology infrastructure Adopt an agile methodology for business and technology implementation Choose a strategic solution for regulatory reporting Adopt data standards across the enterprise Enhance business case of the implementation by including other areas of regulatory reporting under scope Enable curation of rules and business logic with minimal burden on business users Utilize the opportunity to rationalize the regulatory reporting operating model Automation and intelligence (Ai) Knowledge-based management (Ki) Design for experience (Dō) Harness capabilities of an industryleading product in meeting enhanced disclosure requirements out-of-the-box and at an accelerated rate in order to beat the anticipated deadlines by SEC. Leverage Infosys industry knowledge and non-invasive methods for accelerated definition of data flow, business rules, and reporting processes. Adopt a design-thinking-led approach and persona analysis for process harmonization and future-state operating model for regulatory reporting. References https://www.sec.gov/rules/proposed/2015/33-9776.pdf https://www.sec.gov/rules/proposed/2015/33-9922.pdf

About the author Amit Kumar Senior Principal, Infosys Consulting Amit has more than 14 years of business and IT consulting experience working with banking and asset management clients in the US, Japan, UK, and India. His expertise lies in IT strategy, business transformation, and program management, especially in the areas of finance transformation, regulatory reporting, and compliance. For more information, contact askus@infosys.com 2016 Infosys Limited, Bengaluru, India. All Rights Reserved. Infosys believes the information in this document is accurate as of its publication date; such information is subject to change without notice. Infosys acknowledges the proprietary rights of other companies to the trademarks, product names, and such other intellectual property rights mentioned in this document. Except as expressly permitted, neither this documentation nor any part of it may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, printing, photocopying, recording, or otherwise, without the prior permission of Infosys Limited and/or any named intellectual property rights holders under this document. Stay Connected