The Vendor is required to provide an automated solution or solutions for monitoring system employees’ compliance with system personal trading and employee ethics policies.
- The solution or solutions may include single or multiple software systems that monitor employee compliance with system personal trading and employee ethics policies.
- Personal Trading Monitoring Module
• Electronic broker feeds and pre-clearance of personal trades, as follows:
• Electronic pre-clearance of personal trades that are automatically reconciled against rule based restrictions, holding periods, and conflicts of interest;
• Daily updates/refreshes, including personal trading activity and holdings;
• Automated and instant notification of approval or denial of pre-clearance requests via email and the system;
• Post-trade rules testing based upon surveillance of broker feeds;
• Pre-clearance and tracking of private investment transactions;
• Automated third-party broker feeds that provide statements at brokerage account level;
• Ability for users to upload supporting documentation and resubmit investment requests;
• Case management for policy rule triggers and alerts, including workflows for addressing trade policy violations and other multi-tiered notifications (e.g., notices to supervisor, CCO review, closure of review);
• Ability to manually upload broker statements and adjust individual transactions, if needed, for broker feed reconciliation;
• Processing of digital asset (e.g., cryptocurrency) transactions at standards provided for securities, including trading pre-clearance and post-trade monitoring;
• System for managing documents and files provided by users (e.g., trading confirmations, private investment documentation, or other required disclosures); and
• Securities data from global and comprehensive security master and/or vendor feeds, which identify sectors and industries (e.g., GICS or similar classifications).
- Conflicts of Interest Module.
• Outside business activity (“OBA”) monitoring, which provides for:
• Use of customizable forms with various types of mandatory and conditional fields (e.g., text, choice, dropdown, checkbox, etc.);
• Configurable multi-level approval workflows based on an employee’s department, classification, and type of outside employment;
• Options for users to update or terminate previously reported outside activity;
• A user dashboard which provides access to reported, updated, and terminated outside activities;
• Automated notification and reminders of pending OBA disclosures;
• Automated notification of approval or rejection of OBA;
• Periodic pre-scheduled and ad hoc certifications; and
• Custom reports exportable to Microsoft Suite products
- Email Monitoring Module
• Configurable dashboard which displays high-level information regarding keyword and phrases monitoring, including subject lines, relevant keyword “hits,” and employee names/email;
• Customizable keyword searches returned on a real-time basis for emails and messages;
• Customizable statistical reporting functionality into multiple programs;
• Provides for efficient disposition with “select-all” functionality and ability to filter false positives; and
• Custom reports exportable to Microsoft Suite products.
- Contract Period/Term: 2 years
- Pre-Proposal Conference Date: August 12, 2025
- Questions/Inquires Deadline: August 18, 2025
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