Stone House Consulting

Strategic, operational and IT consulting for investment managers and hedge funds

Trade Matching in the Traditional and Alternative Markets

Pressures from investors and regulators are accelerating the pace of convergence in traditional and alternative asset management organizations and improving standards of practice. At present, in the traditional asset management arena, managers’ and brokers’ records are generally compared on a trade-by-trade basis and custodians are authorized by the managers to settle matched transactions. In the hedge fund world, prime brokers, often serving as both trading counterparty and custodian, either settle trades without any affirmation or issue the affirmation on behalf of the manager. After tracing the historical development of these two de facto industry standards, Stone House Consulting partner Holly Miller comments on the role of the administrator, illustrates how the absence of trade matching increases hedge fund managers’ costs, explores why the hedge fund industry has accepted an error-prone process, and outlines a resolution. Read the full article published in the peer-reviewed Journal of Securities Operations & Custody here.

Filed under: Hedge Fund / Alternative Investment Management, Operational Risk, Published Article, Trading and Order Management, Traditional Investment Management, , , , , , , , , , , , ,

Operational Risk #5: Naïve Reliance on Technology—The Downside of Automation

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We’re sorry—the article you are looking for is no longer available on our website.  However, it is included in our book, The Top Ten Operational Risks: A Survival Guide for Investment Management Firms and Hedge Funds.  Purchase your paperback copy or Kindle version!

Filed under: Hedge Fund / Alternative Investment Management, Operational Risk, Operations, Technology, Trading and Order Management, Traditional Investment Management, , , , , , , , , , , , ,

Fixes for Algo Trading Glitches Come from Within

Stone House partner Holly Miller discusses improved controls that can help prevent trading algorithm problems like the one that Deutsche Bank experienced on the Osaka Stock Exchange in June, for which the bank’s wrists were slapped this week. See the article in WatersTechnology’s Sell Side Technology magazine.

Filed under: Operational Risk, Press Coverage, Trading and Order Management, , , , , , ,

Critical Recordkeeping: Trade Tickets and Order Memoranda

It is remarkable the number of buy-side firms that have overlooked the importance of maintaining proper trade tickets and order memoranda in a timely fashion. Three weeks ago, the US Securities and Exchange Commission (SEC) charged New York-based Ark Asset Management Co., Inc. with fraudulent trade allocation as well as disclosure and books-and-records violations. This latter charge involved violations of Section 204 of the Advisers Act and Rule 204-2(a)(3) which requires registered investment advisers to make and keep true, accurate and current order memoranda for the purchase and sale of any security on behalf of a client.

Today many investment managers and hedge funds utilize electronic order management systems to track order creation, modification and deletion as well as trade execution details. These same systems typically will calculate order size, allocate block orders across multiple accounts and track trade execution details. Some more sophisticated systems will further perform pre- or post-trade compliance checks to ensure portfolios remain in compliance with client- or firm-imposed guidelines and restrictions, such as concentration limits or list restrictions (e.g., ‘no tobacco’).

Automated systems, however, can obfuscate for some just what is happening and the information required to ensure a firm remains in compliance with the recordkeeping requirement. Likewise, Rule 204-2(a)(3) is clear as mud for many. So we shall try to shed a little light on best practice for this aspect of maintaining books and records.
Read the rest of this entry »

Filed under: Hedge Fund / Alternative Investment Management, Operations, Trading and Order Management, Traditional Investment Management, , , , , , , , ,

Operational Risk, Investor Communication and Requirements Survey

Please participate in our industry survey on operational risk, investor communication and requirements. The survey is open to investors, managers, custodians, prime brokers, fund administrators, auditors, software vendors, consultants, verifiers and all other industry participants. In appreciation for your time, participants will receive a summary report of survey results and will be entered into a drawing to win a flip camera. Additional details on the survey can be found here.

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