Sec Employee Personal Trading Compliance Requirements

One of the main issues impacting compliance officers today is the difficulty of monitoring the personal trading activities of employees in accordance with best practice and industry regulations. Adherence to rules such as SEC Rule 17j-1 and Rule 204A-1 and adoption of the best practices recommended by the SEC can be very time consuming and distracting for any compliance department.
The main requirements of an Investment Adviser under rule 204A-1 and Rule 17j-1 are:
Adoption of Code of Ethics.
Process to monitor employee personal trading
Reporting by all access persons of all holdings within ten days of becoming an access person and at least once within each twelve month period thereafter.
Submission of transaction reports by access persons no later than 30 days after the end of each calendar quarter. The report must cover, at a minimum, all personal trading transactions during the quarter.
Trade Pre-Clearance approval of certain investments. Access persons must obtain approval before they directly or indirectly acquire beneficial ownership in any security in an initial public offering or in a limited offering.

The SEC when amending rule 17j-1 in 2004 also recommended that Investment Advisers adopt the following in their code of ethics.
Prior written approval before access persons can place a personal securities transaction (“pre-clearance”).
Maintenance of Restricted lists e.g. Lists of issuers of securities that the Registered Investment Adviser firm is analyzing or recommending for client transactions, and prohibitions on personal trading in securities of those issuers.
Maintenance of “restricted lists” of issuers about which the Registered Investment Adviser has insider information, and prohibitions on any trading (personal or for clients) in securities of those issuers.
Blackout periods when client securities trades are being placed or recommendations are being made and when access persons are not permitted to place personal securities transactions.
Reminders that investment opportunities must be offered first to clients before the Registered Investment adviser or its employees may act on them, and procedures to implement this principle.
Prohibitions or restrictions on short-swing trading and market timing.
Requirements for employees placing personal trades to trade only through certain brokers, or limitations on the number of brokerage accounts permitted.
Requirements to provide the adviser with duplicate trade confirmations and account statements.
Procedures for assigning new securities analyses to employees whose personal holdings do not present apparent conflicts of interest.

There are many Personal Trading or Compliance Management systems which allow firms to automate this employee personal trading process. These systems vary from systems which capture employee brokerage statements to systems which allow you to provide end to end employee personal trading surveillance.

The Basic Duties of Insurance Brokers

Insurance brokers who are commonly referred to being insurance agents are the link between clients and insurance providers. An insurance broker has to have sufficient knowledge of the insurance market trends in order to be able to design an insurance policy for a client.

They have to collect data on the client and evaluate their needs as well as the risks involved. They must evaluate the value of various insurance policies and compare them according to the cover level as well as price.

While they arrange the cover for clients they must submit all details of the clients to the insurance providers. They have to negotiate the terms of insurance policy with the insurers to get the best deal for their clients. They even have to renew or adjust policies they have provided.

Insurance brokers must meet the legal requirements while designing an insurance cover. They have to have thorough knowledge of the methods of premium collections as well as how each account is processed. These sales agents must advise clients as to how to make a claim according to their policy. They have to be able to complete all records of the insurance covers they provide by issuing documentation, inputting information on computer systems and saving in record form all the details. They must also prepare detailed reports for insurance underwriters as well as insurance surveyors in various complicated cases.

These insurance sales agents normally provide general insurance covers for individuals and organizations. This includes insurance policies for vehicles, homes, travels, property, business, life and even pets.

Keep in mind that when it comes to commercial insurance these agents have to deal with more complex subjects for insurance such as life insurance for celebrities or very large insurance cover plans for huge industries.

Insurance brokers have to be able to prove their reliability. They have to have the ability to design as well as define each policy cover required by a client according to their respective needs.

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Day Trading – Is Forex Easier To Trade Than Stock Market Indices

There are many professional day traders out there who focus all their efforts on trading a particular instrument, whether it’s a currency pair or a stock market index. I personally have attempted to trade both in the past so I can speak from experience when I say that in general it is much easier to trade forex.

The main reason why is because when you trade one of the major currency pairs you can usually concentrate purely on technical analysis. In other words when you trade the intraday charts you can trade the forex pairs around pivot points and areas of support and resistance because the price movements can be quite predictable. However when you trade stock indices such as the FTSE 100 or the Dow Jones, for instance, the price movements are not always so predictable.

That’s obviously because these indices are made up of various different stocks and they don’t always rise and fall in tandem with each other. Yes you may get some days when all the constituents trade higher or lower, but most of the time certain sectors will be strong, whilst others may be flat or trading lower. Plus there are often occasions when individual stocks release some news concerning their company and as a result the share price moves independently of the wider market.

As a result of all this, you don’t always get as many predictable bounces off key support and resistance levels, for example, as you do when you trade the major forex pairs. Therefore they are much harder to trade with any confidence because you can never be sure of how the price will react around these key levels.

Another point worth making is that when you trade forex you can pretty much guarantee that you will have a large trading range for many of the most popular currency pairs, such as the GBP/USD, EUR/USD and GBP/JPY pairs, for any given trading day. The same cannot be said for the various stock market indices, however, because there are some days when the FTSE 100, and even the Dow Jones, will trade within a very narrow trading range.

So the point I want to get across is that on the whole it’s a lot easier to day trade the forex markets than the stock market indices. They respond very well to technical analysis, whether it’s fibonacci levels, pivot points, or simply trend lines and basic levels of support and resistance, whereas the same cannot always be said about the indices because of how they are derived.

Types of Travel Insurance

Travel insurance policies provide at least six types of coverage, intended for different types of travelers and trips:

Comprehensive medical travel insurance is for people who don’t have any other medical insurance, even at home. Since most people who can afford it have health care coverage in their home country, often through their employer, comprehensive travel medical insurance is mainly of interest to long-term travelers who’ve left their jobs and lost their insurance coverage at home, or to those living and working outside their country of citizenship or permanent residence.

Emergency medical travel insurance is for people who have medical coverage at home, but whose health plan at home doesn’t cover them while they are travelling. Emergency medical travel insurance only covers emergency services abroad; once you get home, you’re back under your regular home coverage for any necessary follow-up treatment or continuing care. Check with your current insurer before you waste money on an emergency travel medical plan that duplicates your existing coverage.

Medical evacuation travel insurance covers the cost of an air ambulance, attending physician and nurse, etc. if you are so badly injured, or become so ill, that you can’t come home or get to a suitable medical facility on a scheduled commercial passenger flight. Even very badly injured travelers usually can come home on regular flights after no more than a couple of weeks of emergency treatment and stabilization abroad. Some of the activities most likely to lead to a need for medical evacuation, such as scuba diving and extreme sports, are often excluded from medical evacuation coverage.

Trip cancellation and interruption travel insurance covers the cancellation or refund penalties and the cost of getting home if you have to cancel your trip, or cut it short, for specified reasons. The covered reasons vary, but typically include injury or illness to you, a travelling companion, or a member of your immediate family. War and terrorism may or may not be included, or may be covered only at additional charge.

Supplier default insurance covers any money you lose because of the bankruptcy of an airline, cruise line, tour operator, or other provider of travel services. Some travel insurance companies no longer offer it at all, while others pick and choose which travel suppliers they will insure.

No matter which type of travel insurance you go for, make sure you read the fine print!

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It is very essential to have a travel insurance policy. Author Pranav Sharma is an experienced insurance professional and widely read expert on general insurance based in Mumbai. Pranav helps readers opt for best .

Benefits Of Jewellery Insurance

Every household family in India carries gold and diamonds in form of jewellery or as a solid brick to make an investment. Probably apart from house, this is the second most precious thing in a family. Hence, to safeguard requires is Jewellery Insurance. Many people may take it as vague idea, but yes it not only gives safety but also helps in covering loss in event of any unfortunate circumstance. Jewellery insurance is not been covered by all insurance companies but a select few with the fine terms which needs to be read before declaring value and making jewellery insured.

The first and foremost benefit is of course the safety part. If a household carries jewellery worth Rs. 5 Lakh and a special occasion like marriage is due in family, its advisable to protect one from unforeseen circumstance by going in for jewellery insurance.

The process of obtaining insurance on jewellery starts with furnishing of invoice of the jewellery to the insurance company. The Insurance company then carries on valuation of jewellery by the empanelled jewellers. Once formalities done, the insurance company determine the Insured declared value. Next, comes reading and signing the declaration. Its vital to read the terms carefully as historically over 25% of the claims gets rejected in India due to faulty insurance policy or unawareness by signing on the consent form without reading the terms and conditions. It leads to not only loss in premium but also give one hassles and mental agony at the claim process. Its also advisable to take couple of snaps of the jewellery for your own record too while making them insured.

Do not follow with that insurance company which offers only the lowest premium but check the past track record in terms of claims and the service levels. Never get carried away with the low premium, there could be wide differences in the premium and claim service levels. Always, have a comparative view in respect to the multiple insurance companies and choose one which you feel is the best in service levels and claim track record.

Also, one may too get a valuation done of the jewellery through his own jeweller before going in for the insurance. As these jewellers are in this business, its best to take there advise and gives it weight for choosing insurance on the gold ornaments. Remember, insurance could act as slight expense in the beginning but it prevents one from a casualty. Take a positive side and have a peace of mind.

FOREX Day Trading – The Dangers of Curve Fitting

In Forex day trading you see many systems that have fantastic track records in back testing, yet they can never match this performance in real time and the trader wipes out his equity.

The reason for this is the concept of curve fitting – if you don’t understand its significance you will lose.

Many traders buy hypothetical track records, or devise their own by running their signals over past data and any track record in day trading is curve fitted.

Why?

Day trading by its very nature doesn’t work.

You never get a real time track record of profits, so any track record has to be curve fitted to make a profit.

So what is curve fitting?

It means fitting the trading signals to the data ( you can of course do this on past data as you know the closing prices ) and making sure that the track record is profitable.

It’s very similar to shooting at a barn door and then drawing a cirlce around each one, after the shots are fired to amek them all bulls eyes.

Of course bending the system to fit the data doesn’t work and profitability is simply an illusion.

Examples of curve fitted systems are

Ones with lots of rules and parameters, or unique rules and parameters for different trading conditions, or contracts.

If you curve fit a system, be it in day trading or long term trend following, it will lose.

No reliable data

Day traders have to curve fit in hindsight to make a profit, as in real time volatility is random and its impossible to predict price direction.

To make money in any form of trading you need to play the odds and you can’t do that in day trading.

When you buy one of those enticing day trading systems offering you 100% profits or 70% success rates ask for the real time track record and you won’t get one.

The one presented to you is hypothetical and done knowing the closing prices and has been curve fitted.

Try and trade any day trading system from a vendor in real time and you can kiss goodbye to your account equity. Don’t fall for the hype of day trading systems see the reality, which is a sure fire way to lose all your money quickly.

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Is Whole Life Insurance Investment a Worthy Investment

A whole life insurance investment is a relatively simple concept. You will be presented with a product that has a set premium and you will be paid the agreed upon amount of the death benefit at the end of the policy holders life. You will also have an investment component included in the policy. All money you contribute over and above the premium will be placed into a cash value account which is then invested on your behalf by the insurer.

Apart from providing you with cash value account and a guaranteed death benefit to leave to your heirs a whole life investment has some other features as well. You have the option to borrow against the cash value your policy or fully withdraw an amount if you have an emergency need for the funds available during the life of the policy.

The theory behind a whole life policy is that it will pay out set death benefit and a cash value to your beneficiaries all while you are guaranteed a set, unchanging premium for the life of the policy. It does more than this, though, when you consider the fact that all the money is tax free and/or tax deferred.

Because of this tax free feature you will have the ability to make a portfolio that can achieve a number of goals that you otherwise may not be able to. You can actually use the whole life policy to secure a smooth succession in the case of a family owned business or to protect your other assets.

You may be met with derision about your interest in a whole life insurance investment by detractors who say that it isnt a real investment because it isnt run like ones stocks, bonds, and mutual funds. While it may not grow that fast, it has the potential to a much safer long term investment since it is done in a safer manner that is designed to ensure your money keeps growing despite market ups and downs.

A whole life insurance investment policy is generally seen as a “savings asset” as opposed to an “investment asset” because your money is saved and grown in a much less aggressive fashion than regular stocks and bonds. With a whole life insurance policy your additional money will be placed into a savings account where it will accrue interest. You dont have to invest the money within this savings account, but you can do so if you wish to. The savings account on its own, though, will become a huge asset over time.

IRS Pursues FBAR Foreign Bank Account Reporting of U.S. Taxpayers

Undisclosed Offshore Accounts are being hunted down with FBAR (Foreign Bank Account Reporting) information requests of U.S. Taxpayers suspected of hiding assets in the wake of the UBS AG fallout and IRS Offshore Settlement Initiative.

What is in store for undisclosed account holders?

In 2009, the IRS and U.S. Department of Justice commenced a highly publicized investigation into Swiss bank UBS AG and U.S. account holders who essentially hid their assets from the U.S. Government. However, the investigation did not conclude with UBS. To entice taxpayers to come clean and disclose their foreign assets in exchange for lesser penalties, the IRS instituted the Offshore Settlement Initiative Voluntary Disclosure Program (the Initiative). Although the deadline to participate in the Offshore Settlement Initiative is long gone, it is clear that offshore tax evasion will continue to be a top IRS enforcement priority. Now, what can U.S. taxpayers with undisclosed offshore accounts who did not make the October 15, 2009 Offshore Settlement Initiative deadline expect coming up?

The IRS will be ramping up their Information Document Requests or IDRs targeting offshore bank accounts.Taxpayers may receive a Form 6564, Information Document Request, to obtain necessary books, papers, and other information relevant to the IRS examiner inquiry into the truthfulness of a tax return. The Information Document Request is a proper and structured process for the IRS to request and get information from taxpayers, including information regarding offshore bank accounts. Although not as formal as a subpoena, an IDR carries with it consequences for failure to comply and can lead to further inquiry and possible sanction.

The IRS will focus Information Document Requests on U.S. taxpayers with offshore assets and accounts that failed to disclose these interests to the U.S. government on their Form 1040, U.S. Individual Tax Returns, and file a corresponding Form TD F 90-22.1, Foreign Bank Account Reporting FBAR. If IRS agents discover that a taxpayer has not reported an interest in an offshore account or income accruing on such accounts during the course of an audit, the IRS may impose steep penalties including the greater of $100,000 or 50% of the offshore account balance for willful failure to file an FBAR for each account. These penalties, compounded with interest and fraud penalties, can essentially wipe out the taxpayers foreign assets. Additionally, taxpayers could be subject to criminal prosecution and jail time for tax evasion.

The issues surrounding these IDRs are extremely delicate and should be approached with considerable caution. Taxpayers who have been sent an Information Document Request by the IRS are best served by getting in touch with a tax attorney who is experienced at resolving disputes with the IRS quickly. An attorney can direct the taxpayer how best to answer an Information Document Request and will be able to talk with his attorney the most appropriate course of action. Otherwise the Internal Revenue Service can seek formidable fines and possible criminal prosecution against those U.S. Taxpayers believed to be hiding assets in undisclosed offshore accounts.

Using The 50-day Moving Average In The Stock Market

As your stock moves up in price, there is a key line you want to watch. This is the 50-day moving average. If your stock stays above it, that is a very good sign. If your stock drops below the line in heavy volume, watch out, there could be trouble ahead.

A 50-day moving average line takes 10 weeks of closing price data, and then plots the average. The line is recalculated everyday. This will show a stock’s price trend. It can be up, down, or sideways.

You normally should only buy stocks that are above their 50-day moving average. This tells you the stock is trending upward in price. You always want to trade with the trend, and not against it. Many of the world’s greatest traders, past and present, only trade or traded in the direction of the trend.

When a successful stock corrects in price, which is normal, it may drop down to its 50-day moving average. Winning stocks normally will find support over and over again at that line. Big trading institutions such as mutual funds, pension funds, and hedge funds watch top stocks very closely. When these big volume trading entities spot a great stock moving down to its 50-day line, they see it as an opportunity, to add to, or start a position at a reasonable price.

What does it mean if your stock price slices downward through it’s 50-day line? If it happens on heavy volume, it is a strong signal to sell the stock. This means big institutions are selling their shares, and that can cause a dramatic drop in price, even if fundamentals still look solid. Now, if your stock drops slightly below the 50-day line on light volume, watch how the stock acts in the following days, and take appropriate action if necessary. Be objective in your stock market decisions.

It Is Now Easier To Get A Wachovia Loan Modification

Frustrated borrowers stuck with the risky and unaffordable Pay Option ARM loans may be getting a break on their applications for a Wachovia loan modification. The recent final approval for the purchase of Wachovia by Wells Fargo Bank may open the door for a more aggressive loan modification program for homeowners facing default on their mortgage loans. Prior to the announcement of the purchase, Wachovia had implemented a beneficial loan workout program that offered their clients a low, step rate loan modification to help them avoid foreclosure and stay in their homes.

However, during the finalization of the Wells Fargo take over, borrowers experienced an extremely uncooperative response when applying for a Wachovia loan modification. The previous program was discontinued, and borrowers were routinely told that Wachovia was not offering any type of loan modification program to needy borrowers. The most a homeowner could hope for was a payment deferral or repayment plan. These two options are short term solutions at best, and not beneficial to the majority of borrowers as a long term solution.

Now that shareholders have given the final approval for the buy out, predictions are that a more aggressive Wachovia loan modification program will be implemented to quickly resolve the high default rate on Pay Option ARM loans written for the majority of Wachovia customers. Wells Fargo $12.7 billion acquisition faces immediate stress as home foreclosures keep rising and unemployment forecasts paint a dim, and lengthy recession threat.

Wells Fargo now owns $482.4 billion dollars in a loan portfolio that will produce $60 billion in losses over the next three years, and about 60% of that will come from the Pay Option Arm mortgages. That is a big incentive to find a cost effective, far reaching and streamlined Wachovia loan modification program to help the lender get those bad loans off their books. Homeowners who have been facing a brick wall may now find that they will have the opportunity to obtain a loan workout to avoid foreclosure and stay in their home.

Borrowers trying to get a Wachovia loan modification will have to be patient and persistent for now. There is no time line in place yet, however homeowners who are actively pursuing a loan workout with Wachovia should stay the course and work within the current system so that they will be in position to move forward as soon as any new program is implemented. Wells Fargo will have to make some tough decisions on how to best write down these loans, but borrowers could see a real benefit as the lender moves forward to clean up the mess they inherited.