Personal Trading Assistant A

COMPLIANCE

PERSONAL TRADING ASSISTANT

Personal Trading Assistant B

COMPLIANCE

PERSONAL TRADING ASSISTANT

Personal Trading Assistant1

What is Protegent PTA?

FIS’ Protegent PTA is a browser-based application that automates compliance with personal trading regulations covering the full spectrum of regulatory agencies, self regulating organizations, and a firm’s specific code of ethics and policies. Protegent PTA provides a centralized location to streamline all aspects of employee facing compliance for financial services organizations including Investment Advisors, Mutual Funds, Broker/Dealers, Ratings Agencies, Insurance Companies, Hedge Funds, Investment Banks, and Private Equity Companies.

● Automated loading of employee brokerage account data – executed transactions, holdings, and current positions.

● Online Employee pre-clearance and confirmed trade capture electronically via overnight trade, position, and account feeds.

● Attach and track Broker Statements online.

● Trade monitoring and analysis with over 180 configurable rules.

● Standard and Custom Certifications including Initial and Annual Holdings, Broker Accounts, Quarterly and Annual Transactions, Code of Ethics and Policy Attestations and Annual Compliance Questionnaires.

● Firm specific Disclosure attestations including Gift & Entertainment, Outside Activities or Directorships, and Political Contributions.

● Library of standard regulatory reports in addition to custom query creation exportable to Excel or PDF.

● Real-time Dashboard Alerts create daily task lists and targeted notifications for follow up.

● Policy violation case management to record recommended actions and evidence of review.

● Automated Overdue Certification reminders.

● Reportable audit and history logs on system actions.

● Scalable solution using advanced, proven technology (Java EE, JBOSS, SQL Server).

● Easily integrates with firm trade and order management systems and HR systems.

● Manage multiple Policies in a single enterprise site by group, jurisdiction, reporting, or business line.

Benefits of PTA

Designed specifically to allow compliance a central location to monitor and manage employee trading activity, Protegent PTA helps ensure compliance with regulatory requirements and individual firm mandates.

● Comprehensive surveillance and alerts to help avoid regulatory fines.

● Reduced compliance paperwork.

● Streamlined workflow.

● Improved visibility into employee personal trading.

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Protegent PTA provides a centralized location to streamline all aspects of employee facing compliance for financial services organizations

Real-Time preclearance requests

Each time a user wishes to make a personal trade, a request is entered into the system and tested against multiple “rules” including regulatory mandates, code of ethics policies and/or standard trading practices. Compliance officers may choose to have completely automated preclearance processing, a manual approvals process, or a mix of both based on certain trade parameters. The simplified entry screen helps enable employees to quickly submit preclearance requests.

Personalized dashboard

Customers can configure the Protegent PTA dashboard to target relative, timely, and actionable aspects of their employee monitoring program. Documents, contacts, and news and information appear upon login and are updated in real time.

Users can configure the Daily Summary to display items of interest, or items that require action, for each specific role within the application. The Compliance calendar can be utilized to schedule and track upcoming tasks.

Compliance users have additional capabilities to create custom dashboard modules using the integrated Query Builder. These modules are often used to track Certifications during reporting periods, top trader activities, or groups of employees in a convenient location.

Sample dashboard

Real-time preclearance analysis

Entry screen sample

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Restricted Security ListsProhibits employees from trading either specific security types or individual securities.

Short-SwingsFlags any employee who has made either a purchase and sale or sale and purchase of the same security during a specified period.

Short-Swing ProfitsNotifies compliance of an employee who has profited from either a purchase and sale or sale and purchase of the same security during a specified period of time.

Short SellingIdentifies when employees are engaging in short selling activities. The check can be limited to include only certain securities.

Excessive Trading RulesSeveral Excessive Trading Rules can be used by compliance to monitor the frequency of employees’s trading activity. Dollar value, number of shares, and total quantity can be monitored.

Protegent PTA rules

Protegent PTA gives Customers complete control over an extremely powerful rules validation engine, helping enable granular definition of rules and rule arguments for transaction analysis. The configurable rules engine helps enable firms to quickly update rules and apply them to any or all user levels, including employees, groups, and/or corporate entities.

Rules include:

Blackout PeriodProhibits employees from trading securities which have been bought or sold in client or firm accounts.

De MinimusAllows for pre- and post-trade clearance on trades that are less than a certain number of shares or dollar amount.

Open OrdersProhibits employees from trading securities for which the firm currently has a pending order.

PreclearanceRequires an employee to obtain permission before making a personal trade by entering an online preclearance trade request.

Confirmation analysis

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Reporting capabilities

Protegent PTA provides users with several types of reporting functionality. Standard reports are available to meet common audit and regulatory requests and the Query Builder tool allows customers to create their own custom searches. Where standard reports are available, any predefined schedules can be set up to automatically send to a compliance e-mail box or via encrypted methods for reports containing sensitive data. Reports can be exported into either PDF or Excel (.csv) format for management reporting or additional offline filtering. Standard reports include:

● Front-running

● In and out trading

● Overdue certifications

● Restricted list holdings

● Executed trade validations

● Preclearance validations

The Reports Reference Guide encompassing the full report library is available upon request. The guide provides a detailed explanation for each available report.

Built-In Query Builder tool

Query Builder is a data retrieval tool for the creation of custom queries within Protegent PTA. Replacing the need for internal IT department report creation, the tool allows for targeted searches, advanced data manipulation, and the ability to both save common queries or respond quickly to a one-off request. Query Builder is most commonly used to shorten the timeframe to produce relevant results for:

● Forensic analysis

● Internal or external audit response

● Management requests

These queries can be saved and reused for regular or consistent requests. Common queries can be shared among the Compliance group for dashboard module creation. Like most Protegent PTA screens and all reports, the results from the custom query are exportable to Microsoft® csv or Adobe PDF formats.

Sample report

Custom query sample

Entry screen sample

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Custom disclosures

Protegent PTA provides the ability to create Custom Disclosures, which allow employees the ability to voluntarily submit required information. The forms builder allows customers to create forms with a wide range of question and field types for targeted information requests. Similar to questionnaires dispensed through certifications, disclosure responses can be automatically analyzed to determine if any responses require additional scrutiny. These may include:

● Outside business activities

● Gifts and entertainment

● Political contributions

● New employee forms

● Directorship requests

● Insider information

● Employee voting

Case Management

In some instances, infractions are not based on a single event and the need to manage cases based on a series of events is needed. Protegent PTA enables firms to relate several events and manage as a single, comprehensive case. Supporting documentation can be attached to cases and allows Protegent PTA to be the complete source of information related to a given case.

Standard and custom certifications

Standard within Protegent PTA is a package of regulatory templates which can be assigned to employees as either Initial or Annual Certifications. These include Initial or Annual Holdings, Broker Accounts, Quarterly or Annual Transactions, or an Attestation to Policies or the Code of Ethics. Each Certification has a defined reporting period where Compliance can receive regular updates on completion. In addition, automated reminder emails can be set up to target those late responders until completion.

Certifications can be customized to collect information in an easy to use format through the integrated forms builder, These custom Certifications, such as Annual Compliance Questionnaire, can be used for annual attestations or as a confirmation that previously submitted responses over a period of time are accurate.

Case management sample Case entry detail

Certification sample

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Control Room Module

The Protegent PTA Control Room allows firms to take advantage of forensic capabilities outside of traditional transaction surveillance. Delivered as an additional model, advanced surveillance capabilities leverage market information sourced from Dow Jones News as well as Corporate Actions and Events delivered in tandem with a security reference library from IDC. Protegent PTA has a flexible set of monitoring tools including tests such as Volume and Price fluctuations, irregular trading patterns, and current News intersections to build an Employee Risk Profile. Above Market and Event surveillance, additional analytical tests can be used to identify group pattern trading, potential misuse of Material Non-Public Information, and Conflicts of Interest. All of this information is presented in both a reviewable dashboard format as well as on a Security Analytical screen where all information is presented in an overlay format for a graphical review. This module provides for separate access rights if required and includes:

● Configurable Alerts

● Dashboard (Control Room specific)

● Security Research

● Conflicts Detection

● Market Data Feeds (News, Corporate Actions, Price and Volume)

Document handling

Tracking evidence of review can often leaves companies with several storage locations for associated documentation. Protegent PTA is available to be a repository of documents related to monitoring firm’s personal trading compliance program. Documents can be attached to a number of different types of records within the system. Typical documents tracked include but not limited to:

● Discretionary account agreements

● Private transactions

● Trade confirmations

● Proof of account closure

Automated delivery of employee account information

Protegent PTA can process employee executed trade files, accounts, and positions electronically. FIS has fostered technical relationships with Broker/ Dealers to enable the ability to accept files directly into Protegent PTA where available.. These files arrive nightly to automatically run through the applied rule set and create automated dashboard alerts for Compliance to manage during the next business day. FIS is continually expanding these relationships on a global basis . Availability is contingent upon an agreement between the customer and the Broker/ Dealer. Please contact your FIS Protegent representative for more information.

Statement Tracking

Protegent PTA is designed to automate and eliminate the paper process. Where electronic brokerage feeds cannot be utilized, an online Statement Tracking tool is available to track, request, and report on employee obligations. Reminder emails can be set up to notify employees when a Statement has not been received. Compliance review Statement transaction activity in line with reported activity to ensure the employee has properly cleared personal trading requests.

Adjustment entry detail

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System language configurations

Protegent PTA is now available for deployment in 12 different languages. English, French Canadian, French, German, Italian, Spanish, Swedish, Dutch, Chinese (Simplified), Chinese (Traditional), Korean and Japanese. Localization can be configured by each employee to specify language and date format preferences. This functionally allows for a simplified deployment of Protegent PTA to geographically disperse regions that have restrictions on local language application support.

Implementation and support

Protegent PTA is available as a FIS hosted ASP solution or a client installed solution. The ASP solution provides customers with the ability to offload the burden of application and system support. The customer-installed solution affords customers the same benefits of the ASP solution as well as the ability to manage their own data. With the ASP solution, deployment is performed by experienced staff using proven implementation methodologies with relatively minimal effort required of customers.

Both versions share the same advantage of dedicated Protegent PTA support, which allows customers to quickly interact with support staff and avoid long response times.

Training

The Protegent PTA team equips customers with the tools needed to have users up and running quickly. Designated training plans, partnered with personal facilitation by Protegent PTA trainers, educate users of workflows inherent within their particular roles and responsibilities within the application. These plans also allow firms to easily administer training themselves via the “Train-the-trainer” program.

Protegent PTA spans all areas of personal trading from pre-clearance authorization through post-trade reconciliation and reporting.

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Protegent’s suite of compliance solutions

Protegent Surveillance

As a rules-based and an integrated solution provider, Protegent Surveillance offers the tools necessary to mitigate internal and regulatory risk by:

● Automating the entire compliance process, including suitability review, exception reporting, regulatory and internal auditing, and workflow case management.

● Identifying questionable transactions and position.

● Improving field supervision processes and audits.

● Analyzing customer and account activity against firm defined mandates.

Protegent Customer Onboard

More than a data entry form, Protegent Customer Onboard is a process to manage the end-to-end customer relationship through its wizard based system for client data entry and processing. This automated system:

● Facilitates the opening of new brokerage and nonbrokerage accounts across multiple back-office applications.

● Available as a stand-alone solution or as an integrated component of Protegent Surveillance.

● Helps ensure compliance with FINRA regulations, such as KYC, Rule 2821, OFAC, CIP and AML.

Drawing from over a decade of intellectual capital, Protegent has maintained its commitment to protecting insurance, retail brokerages, and other buy and sell side financial services from the mounting requirements mandated by regulatory bodies, such as, FINRA, SEC, and NAIC. More than ever before, firms need an efficient enterprise-wide surveillance tool to transform the challenges of increasing costs and compliance into a combined solution.

As an intuitive automated system designed to detect, prevent, and document potential regulatory violations, Protegent PTA is the premier solution provider for monitoring firms’ employee personal trading against regulatory and firm defined guidelines.

In addition to the risk mitigation provided by Protegent PTA, FIS’ Protegent offers an integrated paperless solution for trade surveillance, data archiving and reporting, and managing disparate systems.

The combined suite of Protegent solutions can further help firms streamline efforts and embed a culture of compliance. Financial services aggressively seeking to control cost, while meeting the demands of regulators and corporate governance mandates, can turn to FIS Protegent because more than a vendor – it is a trusted partner that can help your firm further mitigate risk and maximize value.

Protegent Trading Compliance

A Web-based surveillance, supervision, and management reporting tool that automates the institutional compliance workflow, and:

● Provides firms with a complete view of an order’s life cycle.

● Captures and integrates data feeds from both market and trade data.

● Provides a consolidated view of orders and executions.

● Allows customers to meet Reg NMS, OATS, and various supervisory requirements.

About FIS’ Trading Solutions

All FIS solutions are built on the foundation of three basic principles, aimed to help businesses make money, save money, and protect their firm.

While Protegent’s suite of compliance solutions help firms protect their firms’ assets, customers, employees, and reputation, FIS’ suite of trading products and services are engineered to provide more than just protection. Designed with a common element at their core – the customer – FIS’ trading solutions help them achieve increased performance, low latency and execution across multiple platforms, instruments and geographies.

A neutral trading environment is an effective way to maximize value by delivering top execution performance to customers, especially in complex industry conditions. By supporting the entire lifecycle of a trade, FIS’ trading products and services are positioned to help customers obtain peak performance in today’s volatile and uncertain markets.

As a full service provider, you can rely on FIS to provide a single point of accountability. We focus on supporting the trade and helping you achieve cost reductions and additional revenue opportunities through FIS’ bundled trading solutions.

About FIS

FIS is a global leader in financial services technology, with a focus on retail and institutional banking, payments, asset and wealth management, risk and compliance, consulting and outsourcing solutions. Through the depth and breadth of our solutions portfolio, global capabilities and domain expertise, FIS serves more than 20,000 clients in over 130 countries. Headquartered in Jacksonville, Florida, FIS employs more than 55,000 people worldwide and holds leadership positions in payment processing, financial software and banking solutions. Providing software, services and outsourcing of the technology that empowers the financial world, FIS is a Fortune 500 company and is a member of Standard & Poor’s 500® Index. For more information about FIS, visit www.fisglobal.com

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