电子间谍，华尔街式

Asset managers have long had to monitor personal trading by portfolio managers and other employees who have access to inside information. Over the past two years, however, they've been forced to get far more serious about the issue. As part of a regulatory crackdown on industry practices in 2004, the Securities and Exchange Commission required fund firms to adopt, and have employees sign off on, codes of ethics that, among other things, prohibit staff from trading ahead of clients. Since then money management firms have been discovering that manually tracking employee trading is a huge headache - one that technology can help cure.

Monitoring personal trading is a complex, time-consuming task. Firms must evaluate which employees are in a position to receive sensitive information, require them to get pretrade approval from compliance officers and check staff trades against the firm's client-portfolio holdings for potential conflicts, both before and after transactions are executed.

Still, only 20 to 30 percent of asset managers use automated systems for pretrade screening, estimates Stephen Messinger, head of Ernst & Young's West Coast asset management advisory practice in San Francisco. Just 60 percent use some form of automation as part of the monitoring process. Many tackle the job through a combination of manual tracking and Excel spreadsheets, he says. But that is slowly changing as a result of both the new regulatory mandate and pressure from clients.

"The initial reaction to the regulatory scrutiny was for people to scurry around and try to address the problems with whatever they could find and throw people at it," says Messinger. "Now firms are looking at how to automate these tedious processes."

"There's a recognition that this is difficult to do on a manual basis," adds Lane Bucklan, general counsel of Iridian Asset Management in Westport, Connecticut. Increasingly, he says, clients are asking in their requests for proposals whether the firm uses an automated platform to monitor employee trading.

Iridian是爱尔兰银行的10亿美元资产子公司，是大约65个汇款管理员中，使用SunGard数据系统的软件，称为Protegent个人贸易助理，监测和自动授权员工交易。Iridian已经向系统编程了有关个人交易的规则，包括雇员可以购买或销售最近由公司交易的安全性的所谓的停电期，并将其与其交易系统纳入禁止活动。根据Bucklan的说法，Iridian还使用该系统使员工电子商人审查并签署其道德准则，并监测其他冲突，例如工作人员是否有经纪公司工作的亲属。

Monitoring systems can also plug into the brokerage firms where employees execute trades. (Many firms require staff to funnel personal trades through one or two brokers to permit easier tracking.) The monitoring software offered by New York-based Wolters Kluwer Financial Services, for instance, features built-in interfaces with eight brokerage houses, including Charles Schwab & Co., Fidelity Investments' discount brokerage arm, and Merrill Lynch & Co., according to Alexander Zelvin, senior product manager for the system, which is called Examiner and monitors the trading of about 100,000 employees at 60 firms. Such links allow for more-thorough examination of completed trades, by making copies of employee statements instantly available to compliance departments, for example.

Monitoring software might not only make it easier to implement existing codes of conduct, it might also let money managers create better rules in the first place. Many firms, for example, restrict all employees from trading certain securities if a few staffers obtain material, nonpublic information about them. Automated systems, however, can be tailored to affect only those employees with insider knowledge.

"A lot of policies have been written with technology limitations in mind," says Marc Epstein, global sales head for StarCompliance, a Rockville, Maryland, firm whose Altaire system is used by about 50 firms with a combined $8 trillion under management. "Now firms don't have to practice collective punishment." i