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PRODUCT CONFIDENTIAL
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page iii
Contents
PRODUCT CONFIDENTIAL
PRODUCT CONFIDENTIAL
Related Documents
The following documents are also part of the Actimize FMC SP documentation suite:
• Actimize FMC SP Installation Guide
• Actimize FMC SP Implementer’s Guide
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 1
SP Solution Models
▪ Ability to create alerts focused on true risk exposures, thereby reducing the number of
alerts and achieving a low false positive rate.
▪ Intelligent scoring algorithms which lead to efficient management of workload.
• Multilingual support – The SP solution supports multiple languages for predefined user data
(resource strings). This means that RCM can display its interface and alert data in languages
other than English. To this end, the metadata is translated to the user’s language.
For more detailed information, refer to the Actimize FMC SP Implementer’s Guide.
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Solution Methodology
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About Scoring Algorithms
• Options Approvals – this issue is covered by models that compare the option trading to the
option approval level.
• Registrations – this issue is covered by models that review licensing, registrations and
appointments for brokers/agents, and determine if a broker is the Registered Representative
(RR) of record for an account.
• Long-Term High-Load Detection – these models review transactions in products with high
upfront sales fees that are designed for long-term investment.
• Mutual Fund Activity – this issue is covered by models that identify mutual fund investment
activity which may result in an economic disadvantage for the customer caused by the size,
class, frequency, or sales charges associated with trades in high load, long-term investments.
• 529 Plans – the 529 Plans issue is covered by a model that identifies 529 Plan accounts
where the administrative state is not the residence of the accountholder. The plans are
maintained under Section 529 of the Internal Revenue Code and are a federal/state tax-
advantaged way to save money for college.
• Variable Annuities – variable insurance products are hybrid investments containing both
securities and insurance features. The insurance features of variable annuities permit the
investor to receive a series of periodic payments from the investment over time and provide a
death benefit to the beneficiary should the investor die during the accumulation phase.
Like securities under the federal securities laws and insurance under state insurance laws,
variable insurance products are sold jointly through broker-dealers and insurance agencies.
In selling securities, broker-dealers must comply with a number of requirements including
having reasonable grounds for believing that the recommendation is suitable for the investor,
providing adequate supervision over salespersons, ensuring that adequate disclosure is
made to customers, maintaining appropriate insurance licensing and maintaining all required
books and records.
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Alert Consolidation
• Recurrence of alerts
Scores are calculated according to a formula that combines the above scoring factors; each
multiplied by its appropriate weight. Authorized users may control the way scores are calculated
by modifying thresholds, weights and other parameters.
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Actimize Sales Practices (SP) and Suitability Solution Guide Page 6
Issue Suppression
• Check Concentration
NOTE:
The following suppression rules for the DAR model group apply only when the previous alert was
distributed on SP 4.0.0 onward (apart from DAR – SSC, SPO or SPC):
Account Risk Suppress
Portfolio Value Suppress
Portfolio Risk Value Suppress
Distinct Product Keys Suppress
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Actimize Sales Practices (SP) and Suitability Solution Guide Page 7
Issue Suppression
alert (Issue Type – in this model SSC)) <=“ % Change in Overall Account Portfolio Risk for a
new issue“ threshold
• If “Distinct Product Keys suppress” is on
All the positions that:
▪ In the current month = position date and the Prev ACR/DAR alert
▪ Have the same Position product key
• If “Last Alert for this account suppress” is on
▪ Current issue month - Prev ACR/DAR alert <= “N Months for generating a new issue”
threshold
In any case, if “Unsuppressed Function Exit Point” = true, generate an issue even though the last
conditions are met.
The Issue Suppression feature includes two exit points:
• Unsuppressed Function Exit Point – overrides all conditions and decides whether to generate
an issue
• SP_ACR/DAR_dist_should_account_generate_issue_main Exit Point – if this exit point
returns True, all other suppression logic is checked. If this exit point returns False, an issue is
not generated
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Actimize Sales Practices (SP) and Suitability Solution Guide Page 8
Actimize Risk Case Manager (RCM)
All thresholds use the default region and are relevant to all models. They can be configured on
the following levels:
• Region
• Model Group Name
• Model Name
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Actimize Sales Practices (SP) and Suitability Solution Guide Page 9
The Broker Risk Dashboard
• View reports for all entities in the selected number of Lookback Months.
• View reports filtered by Risk Score – Sum of Alerts Score or Count of Alerts.
1.11.2 Worksheets
The Broker Risk Dashboard includes the following worksheets:
• Broker Risk
• Brokers Profile Deviation
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The Broker Risk Dashboard
The data in the Brokers Risk worksheet is displayed as a tree map containing brokers that match
the selections in the filter. Once displayed, the user can hover over a broker to view additional
information.
NOTE:
The user can select more than one entity.
The data is displayed in the Brokers Risk worksheet by risk, where the highest risk is first in a
bigger and square and color-coded – red, orange, light green and dark green; Red being a very
high risk and dark green being a low risk.
The Brokers Profile Deviation worksheet displays the Broker data split according to key
indicators.
The data is displayed as the following six separate key indicators lined up in two rows:
• Change in Equity
• Cost to Equity Ratio
• Turnover Rate
• Commission to Equity Ratio
• Account Tolerance to Risk
• Account Portfolio Risk
Hovering over a key indicator displays a tooltip with the following general information:
• Maximum – highest value in chart
• Upper Hinge – upper limit of the box
• Median – median of the data
• Lower Hinge – lower limit of the box
• Minimum – lowest value in chart
Hovering over a specific point displays a tooltip with specific broker data as follows:
• ID – Id of the broker
• Name – name of the broker
• Number of accounts – number of accounts with the Last Profile Date
• Risk score – risk score number
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The Broker Risk Dashboard
• Change in equity – key indicator for Entity for Period per Account with Change in Equity from
profiles
• Turnover Rate – key indicator for Entity for Period per Account with Total Purchases / X
Month Average Adjusted Net Equity from profiles
• Cost to Equity Ratio – key indicator for Entity for Period per Account with Total Cost / X
Month Average Adjusted Net Equity from profiles
• Commission to Equity Ratio – key indicator for Entity for Period per Account with Total
Commission / X Month Average Adjusted Net Equity from profiles
• Account Tolerance to Risk – key indicator for Entity for Period per Account with Account
Tolerance to Risk from profiles
• Account Portfolio to Risk – key indicator for Entity for Period per Account with Account
Portfolio Risk from Profiles
Element Description
Allows undoing or redoing display settings changes according to the latest
Undo/Redo change
Allows you to save a specific display setting and set it as your default
Original View display, enabling personalizing your dashboard using the following options:
NOTE:
• Selecting Other Views Original View (default) reloads the default
display. For example, after erasing the display using Revert, this option
restores the default display.
• Once you have saved custom Views, you can reload them at any point.
Available only for users with AVA Publisher permissions. A user with AVA
Interactor permissions does not see this option.
Edit
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Glossary
Element Description
Downloads the display settings to a file
Download
1.12 Glossary
The following is a list of acronyms and abbreviations used throughout this guide.
Acronym/ Description
Abbreviation
ABS Absolute value
DE Discretion Exercised
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Glossary
Acronym/ Description
Abbreviation
HRS Transaction in High Risk Securities
IO Investment Objective
MF Mutual Fund
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Glossary
Acronym/ Description
Abbreviation
MMB Missed Breakpoint
RR Registered Representatives
SC Short Cover
SP Sales Practices
ST Solicited Trades
TB Trade Blotter
TB Treasury Bill
UL Underlying
VA Variable Annuities
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Glossary
Acronym/ Description
Abbreviation
VHS High-Load Product Switching for Variable Annuities
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Actimize Sales Practices (SP) and Suitability Solution Guide Page 17
Chapter 2: Account Review (ACR) Model Group
2.1 Overview
The Actimize Account Review (ACR) group models include models developed for the primary
purpose of surfacing accounts that require review for potential sales practice abuse.
The Account Review group includes an Account Profile core model and several detection
models. Each detection model is dedicated to the evaluation of issues related to one or more
lines of business. For more information about lines of business, see Section 1.6.1: Lines of
Business, page 4.
Core Aggregations Core Aggregations are the summary calculations that are done at the
account level. This includes monthly summaries from the detailed account
activity such as sum of cash deposits, withdrawals, number of trades, fees,
commissions, commissions waived, net equity, etc. The motivation for
creating the core aggregation is to summarize the data once and then use it
where needed. (See Section 2.3.2: Core Aggregation Attributes, page 24.)
Profile Calculations Profile Calculations are calculations that are done using the Core
Aggregations. The calculations store monthly attributes that are considered
to be part of the Account Profile such as loss in equity, turnover ratio,
tolerance to risk, and others. The analytical models check the change of the
account profile over a period of time. (See Section 2.3.3: Profile
Calculations, page 24.)
Suitability Information The Suitability Information attribute of the core model maintains information
required for suitability checks such as total net worth, liquid net worth,
investment objectives and others. (See Section 2.3.4: Suitability
Information, page 25.)
Suitability of Portfolio and These combined models are designed to evaluate the overall portfolio risk,
Suitability of Variable including margin portfolio risk, and determine whether it is greater than the
Annuities Current account tolerance to risk. (See Section 2.4.2: Suitability of Portfolio and VA
Allocations combined Current Allocations (ACR-SPO), page 29.)
(ACR-SPO) Lines of business:
• Suitability
• Variable Annuities
• Options
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Overview
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Account Review General Attributes & Conditions
Fee-based Account This model is designed to look at fee-based accounts that are non-
Analysis (ACR-FAA) discretionary commission alternative accounts. The model offers both a
regulatory and a business-focused analysis of these accounts. From a
regulatory perspective, it monitors and identifies accounts with low levels of
account activity that may make the account inappropriate for this type of
program. From a business perspective, it looks for and identifies accounts
with high level of activity where the Firm’s periodic fee does not cover the
cost of maintaining the account. (See Section 2.4.9: Fee-Based Accounts
Analysis (ACR-FAA), page 50).
Line of business:
• Fee-Based Account Activity
Carrier/Insurance Each broker that sells variable annuities has to be appointed by each
Appointments insurance company in order to sell their products.
(ACR-VCA) This model is designed to detect VA sales transactions where the RR/agent
(all agents in case of split) on a brokerage account is not appointed by the
insurance company who has issued this contract. (See Section 2.4.10:
Carrier/Insurance Appointments (ACR-VCA), page 52).
Lines of business:
• Registration Activity
• Variable Annuities
Concentration This model generates and alert if an account has highly concentrated
(ACR-SSC) position in single security or sector. Concentration thresholds are set
according to customer age. (See Section 2.4.11: Concentration (ACR-SSC),
page 53.)
Line of business:
• Suitability
Concentrated Positions of This model is designed to detect accounts that lack diversification or are
1940 Accounts overly concentrated. An alert is issued if any single security exceeds a
(ACR-CPM) predefined percentage of the portfolio or if the total of all stock holdings in the
same sector exceeds a predefined percent of the portfolio. (See Section
2.4.12: Concentrated Positions of 1940 Accounts (ACR-CPM), page 58.)
Line of business:
• 1940 Act
2.2.1 Frequency
The Actimize Account Review models are designed to run as a monthly process. The models
analyze the activities for the last month and compare them to the Account Profile.
NOTE:
All data feeds must be available at the time of the Monthly Account models’ execution.
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Account Review General Attributes & Conditions
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Account Review General Attributes & Conditions
2 Income
3 Growth
4 Income or Growth
5 Speculation or Profits
6 Undecided
7 Default
2.2.7.1 Thresholds
Threshold Name Description Default Value
Alert Max Score Maximum alert score value to which the final alert score is 100
compared
Minimum Net Equity A general Account Review threshold that sets the minimum $1000
(Ending) account net equity
Lookback Period for A general Account Review threshold that sets the period 6 months
Prior Alerts used when counting prior historical alerts
2.2.7.2 Scoring
Score Factor Description Scoring Default
Scale Value
Prior Alerts The score value assigned based on the number of prior 1 20
alerts counted during the lookback period for prior alerts
2 40
>2 60
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Account Profile Core Model
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Account Profile Core Model
• Risk Tolerance – the stated level of risk a given customer is willing to accept with respect to
the equity in an account. The risk to the firm is inversely related to the risk the customer is
willing to accept (in other words, a client willing to accept higher risk in the hope of higher
returns is less risky to the firm than a client unwilling to accept any risk).
• Fee Charges – the fee amount assessed to the account. The fee is charged on a periodic
(usually quarterly) basis.
Calculation Logic
1. Take the Net Equity of the beginning of the period.
2. Add all money and securities deposited in the account.
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Account Profile Core Model
Example 1:
One-month adjusted net equity
Month Net Equity Assets In Assets Out Adjusted Net Equity
12/2004 1000 0 0
Example 2:
Three-month adjusted net equity
Month Net Equity Assets In Assets Out Adjusted Net Equity
12/2004 1000 0 0
Calculation Logic
• Net Equity (End) minus Adjusted Net Equity.
Example:
Month Net 12 Months 12 Months Adjusted Net Equity Change in Equity
Equity Assets In Assets Out
12/2004 1000 0
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Account Profile Core Model
Total:
Account Tolerance Risk: (2*16.66%) + (2*16.66%) + (2*16.66%) + (2*16.66%) + (3*16.66%) +
(3*16.66%) = 2.33
Calculation Logic
1. Identify all the securities that are part of the account position.
2. If security is an option and position is short, determine if security is Covered or not using the
following logic:
If security is Call Option then: If position of underlying security Option Quantity * Conversion
Factor then the security is covered.
Else
If security is Put Option then: If position of underlying security is short and ABS (position of
underlying security) ABS (Option Quantity * Conversion Factor) then the security is
covered.
3. For each security, determine the Security Risk based on the security type as described in
Chapter 7: Risk-Related Calculations, page 202, and based on Is Covered indication and
Long/Short indication.
4. If the security is short (quantity < 0) then:
If Security Risk Value Short High Risk Security Threshold, then multiply the Security Risk
Value by Default Short Security High Risk Multiplier Setting.
Else
Multiply the Security Risk Value by the Default Short Security Low Risk Multiplier Setting.
5. Calculate the Account Risk as: Sum (Abs(Sum(Position by Security ID)* Market Value*
Security Risk)) / Sum(Abs(Sum(Position by Security ID)* Market Value))
6. For accounts with Margin Debit > 0, Calculate Margin Risk Multiplier as: Total Equity divided
by (Total Equity – Margin Debit).
7. Assign Margin Risk Multiplier according to the Margin Risk Multiplier Translation based on
translation table:
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Account Profile Core Model
10-20% 1.10
20-30% 1.15
30-40% 1.2
40-50% 1.25
50-60% 1.5
60-70% 2.0
>70% 2.2
Flexibility
The following are set up for Account Profile – Account Portfolio Risk Calculation in the Actimize
RCM (Thresholds > SP Account Review > SPO – Suitability of Portfolio link).
Threshold Name Description Default Value
Short High Risk Security Sets the threshold for the short high risk security value 3
that defines which short security multiplier is used
Default Short Security The value used for the Short Security High Risk Multiplier 3
High Risk Multiplier
Default Short Security The value used for the Short Security Low Risk Multiplier 2.5
Low Risk Multiplier
Max Margin Risk The value used for the Maximum Margin Risk Multiplier 10
Multiplier
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Account Profile Core Model
The following table presents a full example of the calculation of account portfolio risk.
Security Security Name Product Type Long/Short Quantity Price ($) Value ($) Risk Risk Absolute
ID Indication Weighted Value
Total Score Risk
Weighted
Total
Score
D008569 DIANA SHIPPING INC CS Common stock Long 1000 $14.64 $14,640.00 3.01
T006332 ***TRANSOCEAN INC. CS Common stock Long 1000 $53.97 $53,970.00 1.47
C263805 CENTEX CORP CS Common stock Long 1000 $70.67 $70,670.00 1.27
C263805 CENTEX CORP CS Common stock Short 1000 $70.67 ($70,670.00) 3.18
Sum by Position: 0 $141.34 $0.00 0 0
9999999 Cash Cash Long 72000 $1.00 $72,000.00 0
Sum by Position: 72000 $1.00 $72,000.00 0 0
Portfolio Total Value: $152,210.00 Total: 180902.3
Portfolio Risk Value: 1.19
Calculation Logic
1. Identify the risk for each security as shown in Chapter 7: Risk-Related Calculations, page
202.
2. Retrieve all positions of securities which are under Brokerage Account only and with Security
Risk > High Risk Security Determination threshold.
3. Accumulate all the positions using Sum (ABS (Sum (Position of the Same Security) * Market
Value)).
Flexibility
The following threshold is set up for Account Profile Suitability Information Calculations in the
Actimize RCM (Thresholds tab > SP Account Review > SPC – Suitability of Portfolio –
Concentration Risk link).
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Detection Models
High Risk Security Determination The minimum risk value that determines whether 3
a security is considered high risk
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Detection Models
In addition to evaluating the overall portfolio, the model checks whether there is a margin debt
that caused the Overall Portfolio Risk to be inconsistent with the account suitability profile
information.
Net equity calculations exclude positions in variable annuities as assets held away.
NOTE:
This model does not reduce the risk value assigned to positions which may be offset by other
security holdings in the portfolio (for example, option spreads. combinations, exotic or
representative derivatives, convertible securities, etc.).
For information about the portfolio risk calculations, see Section 7.2: Portfolio Risk, page 212.
2.4.2.4 Flexibility
Business users can adjust the following settings with the options in the Actimize RCM.
2.4.2.5 Thresholds
This model uses Account Profile thresholds.
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Detection Models
2.4.2.6 Scoring
Score Factor Description Scoring Scale Default
Value
Difference between Score values are assigned based on the 0-20% 20
Account Portfolio Risk difference between Account Portfolio Risk
(or Variable Annuity (or Variable Annuity Contract Risk) and 20-40% 30
Contract Risk) and Account Suitability Tolerance to Risk (as
Account Suitability Ratio to Account Suitability Tolerance to 40-60% 40
Tolerance to Risk Risk)
60-80% 60
>80-100% 80
>100% 100
10-20 1.1
20-30 1.15
30-40 1.2
40-50 1.25
50-60 1.5
60-70 2
>70 2.2
Account Exclusion List Accounts that must be excluded from the analysis User defined
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Detection Models
2.4.3.4 Flexibility
Business users can adjust the following settings using options in the Actimize RCM.
Scoring
Score Factor Description Scoring Scale Default
Value
100-200% 70
>200% 80
Account Total High Risk Score values are assigned based $10,000-$100,000 5
Security Position on the total market value of the
high-risk positions in an account. $100,000-$500,000 10
The higher the value, the higher
the score. >$500,000 15
Portfolio Concentrated Risk Score values are assigned based 0–10% 0.5
Ratio on the account’s portfolio risk that
is calculated based on the volatility 10-20% 1.0
risk value of the stocks
20-25% 1.5
25-30% 2.0
30-40% 2.5
40-50% 3.0
>50% 3.5
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Detection Models
User-Defined Lists
Users can add the appropriate items to the user-defined lists using the options in the Lists tab of
the RCM.
List Name Description Sample Values
Account Exclusion List Accounts that are to be excluded from the analysis User defined
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Detection Models
2.4.4.4 Flexibility
Business users can adjust the following settings with the options in the Actimize RCM.
Thresholds
NOTE:
The Minimum Account Equity threshold used by this model is a General Account Review
threshold (see Section 2.2.7: Account Review General Settings, page 22).
The thresholds for this model group can also be configured according to multiple factors, not only
Investment Objective. These factors can be found in the Threshold by Risk action link in the
RCM Settings Thresholds tab. The following are the values that can be modified.
3 months COR COR threshold for period and Investment Objective category (see 6%
Section 2.2.6: Investment Objective Mapping, page 22)
12 months COR COR threshold for period and Investment Objective category (see 3%
Section 2.2.6: Investment Objective Mapping, page 22)
Scoring
Score Factor Description Scoring Scale Default
Value
COR Value Score values assigned based on the degree 0-10% 40
that the Actual COR differs from the threshold
10-50% 50
50-100% 60
100-200% 70
>200% 80
Income/Growth 20
Income 25
Undecided 25
Preservation of 30
Capital
Default 25
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Detection Models
0.5-1 15
1-1.5 20
1.5-2 25
2-2.5 30
2.5< 35
User-Defined Lists
Users can add the appropriate items to user-defined lists using the options in the Lists tab of the
Actimize RCM.
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Detection Models
4. Check if historical data is available for a 3-month and a 12-month period. If a period does not
have historical data, then the Cost Equity Ratio is not calculated for that period.
5. For each of the three periods, calculate the Cost Equity Ratio = Cost for that period divided
by the Average Adjusted Net Equity.
6. Generate an alert if at least for one of the three periods (Cost Equity Ratio) Cost Equity
Ratio Threshold.
2.4.5.4 Flexibility
Business users can adjust the following settings using the options in the Actimize RCM.
Thresholds
NOTE:
The default value for ACR-CER thresholds is Investment Objective (see Section 2.2.6:
Investment Objective Mapping, page 22, and Section 2.3.1: Account Attributes, page 23). This
value can be modified by the implementer during the implementation phase.
3 Months Cost CER threshold for the period and Investment Objective category 7%
Equity Ratio (see Section 2.2.6: Investment Objective Mapping, page 22)
12 Months Cost CER threshold for the period and Investment Objective category 5%
Equity Ratio (see Section 2.2.6: Investment Objective Mapping, page 22)
Scoring
Score Factor Description Scoring Scale Default
Value
CER Value Score values assigned based on the degree (%) 0-10% 40
that the actual CER differs from the threshold
10-50% 50
50-100% 60
100-200% 70
>200% 80
Account’s Average Score values assigned based on the Net Equity 50,000-100,000 5
Adjusted Net of the account after adjustments for non-trade
Equity activity. The higher the equity, the higher the 100,000-200,000 10
score (see Section 2.3.3.1: Adjusted Net Equity,
page 24). >200,000 15
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Detection Models
Income/Growth 20
Income 25
Undecided 25
Preservation of 30
Capital
1-1.5 20
1.5-2 25
2-2.5< 30
2.5< 35
Account Exclusion List Accounts that must be excluded from the analysis. User defined
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Detection Models
Buy Buy
Buy to Cover
Buy to Open
Buy to Close
Sell Sell
Short Sell
Sell to Open
Sell to Close
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Detection Models
)
OR
(3 Months Turnover Rate > 3 Months Turnover Rate Threshold
AND
ABS (3 Months Total Sales/ Total Purchases Ratio) >= 3 months Sales to Purchases Ratio
Threshold
AND
ABS (1 month TOR) >= Min TOR Threshold
)
OR
(12 Months Turnover Rate > 12 Months Turnover Rate Threshold
AND
ABS (12 Months Total Sales/Total Purchases Ratio) >= 12 months Sale to Purchases
Ratio Threshold
AND
ABS (1 month TOR)>= Min TOR Threshold
)
2.4.6.4 Flexibility
The business user can adjust the following settings using the options available in the Actimize
RCM.
Thresholds
NOTE:
The default value for ACR-TOR thresholds is Investment Objective (see Section 2.2.6:
Investment Objective Mapping, page 22 and Section 2.3.1: Account Attributes, page 23). This
value can be modified by the implementer during the implementation phase.
Minimum Account Age Minimum number of days the account is open. Calculated as 90 days
(Days) the difference between the last business date of the month and
the date the account was open.
1-month Turnover Rate TOR threshold for the period and investment objective. 300%
3-month Turnover Rate TOR threshold for the period and investment objective. 400%
12-month Turnover Rate TOR threshold for the period and investment objective. 550%
PRODUCT CONFIDENTIAL
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Detection Models
3-month Sales to Ratio of total sales (measured in monetary value) to the total 50%
Purchases Ratio purchases (measured in monetary value) for the respective
period. If the total Purchases equal 0, then this threshold is not
applicable. Not used in scoring.
12-month Sales to Ratio of total sales (measured in monetary value) to the total 50%
Purchases Ratio purchases (measured in monetary value) for the respective
period. If the total Purchases equal 0, then this threshold is not
applicable. Not used in scoring.
Scoring
Score Factor Description Scoring Scale Default
Value
TOR Value Score values assigned based on the degree (%) 0-10% 40
that the actual TOR differs from the threshold
10-50% 50
50-100% 60
100-200% 70
>200% 80
Income/Growth 20
Income 25
Undecided 25
Preservation of 30
Capital
1-1.5 20
1.5-2 25
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Detection Models
2.5< 35
User-Defined Lists
Users can add the appropriate items to user-defined lists using the options in the Lists tab of the
Actimize RCM.
List Name Description Example Values
Account Exclusion List Accounts that must be excluded from the analysis User defined
Standard Example
The LIE model generates alerts for accounts that have experienced a percentage loss in equity
exceeding a defined percentage threshold over monthly, trailing 3-month, and trailing 12-month
lookback periods.
For example, for January 2005, the Beginning Net Equity taken from the end of December 2004
is $10,000. At the end of January 2005, this account shows:
• Net equity $7000
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Detection Models
Index2 25%
Index3 25%
Income/Growth Same as above. Different indices and weights can be applied per investment
objective.
Income Same as above. Different indices and weights can be applied per investment
objective.
Account information:
• Beginning net equity = $10,000
• Total deposits = $1,000
• Total withdrawals = $500
• Net equity = $7,000
• Primary investment objective is growth
In this scenario:
• The account’s LIE ratio is -33.3%.
• Based on the investment objective settings, the market was down 20%.
• The market-adjusted LIE equals the account LIE minus the market change. The resulting
adjusted LIE is -13.3%.
Since it does not exceed the threshold (default is set to 15%), an alert is not generated.
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Detection Models
Index3 70%
Account information:
• Beginning net equity = $10,000
• Total deposits = $1,000
• Total withdrawals = $500
• Net equity = $7,000
• The account portfolio is based on equity (50%) and fixed income (50%)
Allocation in Portfolio
Equity 50%
In this scenario:
• The account’s LIE ratio is -33.3%.
• Based on the weighted average according to portfolio holdings, the market was down
11.55%. This is based on the following calculation:
50% * (-20) + 50% * (0.3*-8 + 0.7*-1) = -11.55%
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Detection Models
• The Market Adjusted LIE equals the Account LIE minus the Market Change. The resulting
adjusted LIE is -21.78%, based on the following calculation:
(-33.3%) – (-11.55%) = (-21.78%).
Since the Market Adjusted LIE exceeds the threshold (default is set to 15%), an alert is
generated.
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 44
Detection Models
2.4.7.5 Flexibility
Business users can adjust the following settings with the options in the Actimize RCM.
Thresholds
NOTE:
The default value for ACR-LIE thresholds is Investment Objective (see Section 2.2.6: Investment
Objective Mapping, page 22 and Section 2.3.1: Account Attributes, page 23). This value can be
modified by the implementer during the implementation phase.
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 45
Detection Models
Scoring
Score Factor Description Scoring Scale Default
Value
LIE ratio value Score values assigned based on the degree 0-10% 40
(%) that the actual LIE varies from the threshold
10-50% 50
50-100% 60
100-200% 70
>200% 80
Account’s Adjusted Score values assigned based on the net equity 50,000-100,000 5
Net Equity of the account after adjustments for non-trade
activity. The higher the equity, the higher the 100,000-200,000 10
score (see Section 2.3.3.1: Adjusted Net Equity,
page 24). >200,000 15
< 50,000 0
Income/Growth 20
Income 25
Undecided 25
Preservation of 30
Capital
1-1.5 20
1.5-2 25
2<2.5 30
2.5< 35
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 46
Detection Models
User-Defined Lists
Users can add the appropriate items to the user-defined lists using the options in the Lists tab of
the Actimize RCM.
List Name Description Example Values
Account Exclusion List Accounts that must be excluded from the analysis User defined
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 47
Detection Models
2.4.8.4 Flexibility
Business users can adjust the following settings using the options in the Actimize RCM.
Thresholds
NOTE:
The default value for ACR-LIM thresholds is Investment Objective (see Section 2.2.6: Investment
Objective Mapping, page 22 and Section 2.3.1: Account Attributes, page 23). This value can be
modified by the implementer during the implementation phase.
Income/Growth $100,000
Income $75,000
Speculation/Profits $200,000
Undecided $75,000
Three-month Loss LIM value threshold for a 3-month Preservation of Capital $150,000
in Equity value period and investment objective
category Growth $250,000
Income/Growth $250,000
Income $200,000
Speculation/Profits $500,000
Undecided $200,000
12-month Loss in LIM value threshold for a 12-month Preservation of Capital $250,000
Equity value period and investment objective
category Growth $350,000
Income/Growth $350,000
Income $300,000
Speculation/Profits $1,000,000
Undecided $300,000
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Detection Models
2 Income
3 Growth
4 Income or Growth
5 Speculation or Profits
6 Undecided
7 Default
Scoring
Score Factor Description Scoring Scale Default
Value
LIM value Score values assigned based on Actual LIM $0-$50,000 10
value difference from the threshold.
The scoring scale is from X to Y (inclusive). $50,000-$200,000 15
$200,000-$400,000 20
$400,000-$1,000,000 25
<$50,000 0
Income/Growth 20
Income 25
Undecided 25
N/A 25
Preservation of Capital 30
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Detection Models
1-1.5 20
1.5-2 25
2<2.5 30
2.5< 35
User-Defined Lists
Users can add the appropriate items to the user-defined lists using the options in the Lists tab of
the Actimize RCM.
Account Exclusion List Accounts that must be excluded from the analysis. User defined
PRODUCT CONFIDENTIAL
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Detection Models
NOTE:
The generated alert refers only to the most significant period for each of the following
scenarios. This is the period that has the maximum difference between the scenario’s
result and the threshold.
Number of Trades for the account is below a user-defined Minimum Low Number
of Trades for a Period threshold, or zero.
OR
Number of Trades for the account is above a Maximum High Number of Trades for
a period threshold
OR
If the Fixed Fees Charged > Commissions Waived and the Ratio of Fixed Fees
Charged to Commissions Waived for Under Active Accounts for a period >
Ratio of Fees Charged to Commissions Waived for Under Active Accounts
threshold, up to and including infinity.
OR
If Commissions Waived > Fixed Fees Charged and the Ratio of Fixed Fees
Charged to Commissions Waived for Over Active Accounts for a period the
Ratio of Fees Charged to Commissions Waived for Over Active Accounts
threshold.
NOTE:
If commissions waived is equal to 0 (zero), the system issues an alert.
2.4.9.4 Flexibility
The business user can adjust the following settings using options available in the RCM.
Thresholds
Threshold Name Description Period &
Default Value
Minimum Low Number of The minimum number of trades (for each period set User Defined
Trades for a Period by the user for this threshold; for example, 6, 12 and
18 months) which sets the threshold for under
active accounts.
Maximum High Number of The maximum number of trades (for each period set User Defined
Trades for a Period by the user for this threshold; for example, 6, 12 and
18 months) which sets the threshold for over active
accounts.
Ratio of Fees Charged to The ratio (%) of fixed fees charged over 200%.
Commissions Waived for commissions waived (for each user-defined period
Under Active Accounts for this threshold) which sets the threshold for under
active accounts.
Ratio of Fees Charged to The ratio (%) of fixed fees charged over 50%
Commissions Waived for Over commissions waived (for each user-defined period
Active Accounts for this threshold) which sets the threshold for over
active accounts.
PRODUCT CONFIDENTIAL
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Detection Models
Scoring
Score Factor Description Scoring Scale Default
Value
Number of trades The score values assigned based on the No Activity 25
number of trades during the defined period.
Under-active 20
Over-active 10
NOTE: 50-85% 25
Proportionate scores are given for
intermediate values for this factor. 85-200% 0
Account value falls The score value assigned if the account value -- 10
below Minimum falls below the minimum household total net
Household Total Net equity threshold
Equity threshold
2.4.10.2 Logic
1. Apply Account Review filters.
2. Apply model-specific population filters.
3. For each variable annuity contract, retrieve the insurance company that issued the contract
(from the contract record), and compare to a list of insurance companies that the broker
(primary RR on brokerage account) is appointed with.
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 52
Detection Models
4. Generate an alert if there are one or more contracts issued by an insurance company which
the broker is not appointed with.
2.4.10.3 Flexibility
Enables the business user to adjust the following settings in the RCM UI.
Scoring
Score Factor Description Default
Value
Broker is not appointed Score assigned for each contract where the RR on the 20
with insurance company account is not appointed with the insurance company that
issued the contract
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Detection Models
6. Calculate the Single Security Concentration/Low Priced Security by dividing the ABS of the
underlying product by the specific concentration denominator (such as Net Equity of the
account).
7. Calculate the ABS of the holdings of each criterion. This is done by subtracting the total short
position value from the total long position value of each criterion.
8. Calculate all other concentration criteria (not Single Security Concentration or Low Priced
Security) by dividing the ABS of each criterion by the specific concentration denominator
(such as Net Equity of the account).
9. Count the number of underlying securities for each criterion and store this value (this is done
to exclude duplication of focus issues).
10. Generate an alert if:
▪ Single Security Concentration is above the Single Security Concentration threshold
OR
▪ Other concentration criteria (not Single Security Concentration or Low Priced Security) is
above the criterion’s own threshold
AND
▪ The number of underlying securities per criterion is above the count of mapped threshold
for the criterion and the relevant denominator
2.4.11.3 Flexibility
Thresholds
Threshold Name Description Default Value
% Change in Overall Minimal % change in portfolio risk from previous 30%
Account Portfolio Risk concentration alert for this account. Determines
for a New Issue whether a new alert will be generated.
Calculation: None
Format: Number
All Criteria’s Users can create several criteria using Account N/A – there is no default
Threshold by Risk factors only, except single security and low price. value
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Detection Models
Custom Denominator Enables users to define new denominators. N/A – there is no default
value
Custom Product Enables users to define up to five new product N/A – there is no default
Attribute attributes, for example, User Name. value
Low Price ($) Threshold (Price < threshold) for determining Exchange Value
whether a security is low priced (Penny Stock). Code
(Applies to equities only.)
All 5
Calculation: None
Format: Number
Minimum Account Net This threshold can be set dynamically by account Age Threshold
Equity fields, custom fields, and/or account risk.
Calculation: None 0 $100,000
Format: Number
Minimum Net Worth This threshold can be set dynamically by account Age Threshold
fields, custom fields, and/or account risk. The
default scale is age. 0 $100,000
Calculation: None
Format: Number
Previous Issue The lookback period for the previous alert (in 6
Lookback Period months).
Product Level Enables users to define a threshold for a specific N/A – there is no default
Definition product key (without having to define criteria and/or value
factors).
Sector vs. Net Equity The count of underlying products that were found Age
during the analysis. The default Age factor can be
changed.
Single Security Users can create two criteria: single security or low Age
Threshold by Risk price, each using the Account and Product factors.
Single Security vs. Checks whether the thresholds are exceeded Age
Net Equity based on the factors.
PRODUCT CONFIDENTIAL
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Detection Models
Concentration Criteria
Name Description
Single Security The unique identifier of a financial instrument
Sector The sector or industry that the security belongs to; for example,
pharmaceuticals
Low Priced Security Penny Stock – security with a price lower than a certain threshold
(applicable only to equities)
Overall Low Priced Security Penny Stock – security with a price lower than a certain threshold,
calculated for an entire group of securities
Overall Securities in Watch List 1 The concentration for the overall subtype in the entire watch list
Overall Securities in Complex The concentration of the overall product subtype in the entire
Products List Complex Products List
Scoring
Score Factor Description General Rule Specific Rules
Account Risk Score Score-assigned values based on the N/A Low Value Score
account’s tolerance to risk value.
0.5> 0
Thresholds can be set dynamically by
account fields, custom fields, and/or 0.5-1 15
account risk.
Calculation: Account Tolerance to 1-1.5 20
Risk
Format: Number 1.5-2 25
2-2.5 30
Country vs. Net Score for the country criterion N/A N/A
Equity Score
High-Yield Bonds vs. Noninvestment grade bond from the N/A N/A
Net Equity Score security master; determines S&P
and/or Moody’s and/or other ratings
Issues vs. Net Equity Score for the Issues criterion N/A N/A
Score
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Detection Models
Overall Low Priced Score of overall low priced securities N/A N/A
Securities vs. Net versus the net equity score
Equity Score
Region vs. Net Equity Score of the region versus the net N/A N/A
Score equity score
Sector vs. Net Equity Score values assigned based on the The larger the Scale Score
Score difference between the sector order the
threshold and the section value. higher the 0-10 40
Calculation: Concentration criteria score
10-50 50
concentration differs from respective
threshold 50-100 60
Format: Number
100-200 70
>200 80
Security Type vs. Net Score of the security type versus the N/A N/A
Equity Score net equity score
Single Security vs. Score values assigned based on the The larger the Scale Score
Net Equity Score difference between the underlying order the
security threshold and the underlying higher the 0-10 40
security value. score
10-50 50
Calculation: Underlying security
concentration differs from respective 50-100 60
threshold
Format: Number 100-200 70
>200 80
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Detection Models
Security Types Exclude List of product subtypes that must be excluded from the detection analysis.
List
High Yield Security List of security subtypes that are excluded from the High Yield Bond analysis
Type Exclusion List only.
High Yield Security List of fixed income securities that are excluded from the High Yield Bond
Exclusion List analysis only.
Complex Products List List of security types (Product Subtypes) that are considered Complex
Products by FINRA, IOSCO and other global or bank-specific standards.
PRODUCT CONFIDENTIAL
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Detection Models
OR
If the aggregation for the cash subtype products in the account exceeds the Cash Related
Concentration threshold.
2.4.12.3 Flexibility
The business user can adjust the following settings in the RCM.
Thresholds
Threshold Description Value
Cash Related Maximum tolerated ratio of the total market value of the position 5%
Concentration divided by Account Ending Net Equity
Money Market Maximum tolerated ratio of the total market value of the position 30%
Concentration divided by Account Ending Net Equity
Maximum Allowed Maximum tolerated ratio of the market value of the position for 5%
Single Security each security divided by Account Ending Net Equity.
Concentration
Scoring
The total score of the alert will be determined based on the calculation of the following.
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 59
Chapter 3: Daily Account Review (DAR) Model
Group
3.1 Overview
The Actimize Daily Account Review (DAR) models consist of a group of analytical models
developed for the primary purpose of surfacing accounts that require daily review for potential
prohibited sales practices.
In conjunction with Trade Review and Account Review, this completes the comprehensive
offering for Sales Practices Compliance and provides documentation of appropriate supervisory
review.
PRODUCT CONFIDENTIAL
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Overview
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 61
Daily Account Review General Attributes and Conditions
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Actimize Sales Practices (SP) and Suitability Solution Guide Page 62
Daily Account Review General Attributes and Conditions
3.2.1 Frequency
The Daily Account Review models are all designed to run on a daily basis (T+1).
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Detection Models
Thresholds
Threshold Name Description Default
Value
Lookback Period for Prior Alerts A general Daily Account Review threshold that sets the 10 months
period used when counting prior historical alerts.
Number of days trades Determines the expected maximum latency for a trade. 0
registration is being delayed Latency refers to the period between the Daily Account
Review process date and the Trade Date. If higher
latency is identified, trade is flagged as a delayed trade
(As of Trade).
Alert Max Score Maximum alert score value to which the final alert score 100
is compared
Scoring
The following general scoring factor is applied to all trades in the process of alert generation by
the DAR rule. By default, this rule is activated.
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Detection Models
Although each state determines particular plan features like maximum contribution, there are
some similarities. The following features are common to all 529 Plans:
• Tax-deferred growth of investment earnings
• Federal income tax-free qualified distributions
• No restrictions based on income
• The money can be used to pay for tuition and most plans cover books, room and board and
other qualified higher education expenses
• The money can be used to pay for most accredited colleges and universities nationwide and
does not have to be used at a state school
• Gift and estate tax benefits are available for contributors to the accounts
• The contributor (parent) not the beneficiary (child) maintains control over the account’s assets
Although the contributor does not need to be a resident of the state for which the 529 Plan is
being administered, the contributor should consider whether its home state offers its residents a
plan with alternate state tax advantages or other benefits. For this reason, the model surveils and
raises an alert when the client invests in a 529 Plan from a state that is different from the
contributor’s home state.
3.3.1.4 Flexibility
The business user can adjust the following settings using the options in the Actimize RCM.
Thresholds
This model uses only Daily Account Review general thresholds and settings.
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 65
Detection Models
Scoring
Score Factor Description Scoring Default
Scale Value
Purchase of an out- Score value assigned if there was a purchase of an out- NA 30
of-state 529 Plan of-state 529 plan.
Trade value Score values assigned based on the trade value. The 0-$5K 5
greater the value amount, the higher the score.
$5K-15K 10
> $15K 15
User-Defined Lists
Users can add the appropriate items to the user-defined lists using the options in the Lists tab of
the Actimize RCM.
List Name Description Example Values
529 - Account Exclusion List Accounts that must be excluded from the analysis User defined
PRODUCT CONFIDENTIAL
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Detection Models
3.3.2.4 Flexibility
The business user can adjust the following settings using the options in the Actimize RCM.
Thresholds
Threshold Name Description Default Value
Minimum Number of Determines the thresholds for the number of transactions for 15
Transactions the lookback period
Minimum Value of Determines thresholds for the value of transactions for the $80,000
Total Transactions lookback period
Minimum Ratio Determines the threshold for the ratio of buys/ins over 75%
between Buys/Ins sells/outs (%)
and Sells/Outs
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Detection Models
Level of the alert Determines the detection aggregation level; the model can be Fund
set to one of the following:
Fund – analysis for market timing within a specific fund
Fund_Family – analysis across all funds in a family
Multi_Family – analysis across families
NOTE:
Transactions are defined as buys and sells.
Scoring
Score Factor Description Scoring Scale Default
Value
Degree of Score values assigned based on the percentage >10%-50% 10
Violation by which the number of transactions threshold
was violated. >50%-100% 20
The higher the percentage, the higher the score.
> 100% 25
>95% 25
Activity Value Score values assigned based on the total value 0 to $100,000 5
of the transactions involved in the activity.
The higher the value, the higher score. >$100,000- $500,000 10
>$500,000 25
User-Defined Lists
Users can add the appropriate items to the user-defined lists using the options in the Lists tab of
the Actimize RCM.
MKT - Account Exclusion List Accounts that must be excluded from the analysis User defined
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 68
Detection Models
If, in the example below, an account has Approval Level 4, this includes all activities of Approval
Level 3 (Covered Call, Long Put/Call and Naked Put) plus the addition of Combinations. If the
account holds an option position that is a Naked Call Write, an alert is generated. However, if the
account has Approval Level 4 and holds an option position that is a Covered Call, no alert is
generated.
Level of Approval
Strategy Level 0 Level 1 Level 2 Level 3 Level 4 Level 5
Covered Call * * * * *
Long Put/Call * * * *
Naked Put * * *
Combinations * *
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Detection Models
NOTE:
This model assumes that all option contracts will be for 100 shares. If fractional contracts are
allowed, the scenarios must be changed. Also, only long positions of UL are said to cover
SC, not short positions of UL.
Approval Level 2 - Long 1. If Position Type = (Long Call or Long Put), then option position is
Call/Long Put/Covered Put allowed.
Else
If Position Type = (Short Call), determine if the position is covered
as described in Approval Level using the above logic.
Else
Check if Short Put position is covered, as follows:
2. Determine Total Option Contracts = sum of all Short Put Option
Position Quantity (including the appropriate quantity sign) for the
underlying Security that is the same as the checked position.
3. Determine Total Underlying Quantity = sum of all Underlying
Position Quantity (including the appropriate quantity sign) for the
underlying Security that is the same as the checked position.
4. If (Total Underlying Quantity < 0
AND
(Total Option Contracts)*Conversion Factor Total Underlying
Quantity), the short put option position is covered.
5. If not covered, then this Short Put option position is not allowed.
Approval Level 3 - Naked Put • If Position Type = (Long Call or Long Put or Short Put), then
option position is allowed.
Else
• If Position Type = (Short Call), determine if the position is covered
as described in Approval Level using the logic above.
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Detection Models
Approval Level 4 - 1. If Position Type = (Long Call or Long Put or Short Put), then
Combinations Scenario option position is allowed.
Else
If Position Type = (Short Call), determine if the position is covered
as described in Approval Level using the logic above.
Else
Determine Total Short Call Option Contracts = sum of all Short
Call Option Position Quantity (including the appropriate quantity
sign) for the underlying Security that is the same as the checked
position.
2. Determine Total Short Put Option Contracts = sum of all Short Put
Option Position Quantity (including the appropriate quantity sign)
for the underlying Security that is the same as the checked
position.
3. If number of Total Short Call Option Contracts > Total Short Put
Option Contracts then this Short Call option position is not allowed.
3.3.3.5 Flexibility
Business users can adjust the following settings using the options available in the RCM.
Thresholds
This model uses only general thresholds and settings.
Scoring
Score Factor Description Scoring Scale Default
Value
Unapproved position Score values assigned based on the Level Level 0 100
of Approval.
The lower the approval level, the higher the Level 1 80
score.
Level 2 70
Level 3 60
Level 4 70
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Detection Models
>4 5
User-Defined Lists
Users can add the appropriate items to the user-defined lists using the options in the Lists tab of
the Actimize RCM.
Account Exclusion List Accounts that must be excluded from the analysis User defined
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Detection Models
3.3.4.3 Flexibility
Business users can adjust the following settings in the RCM.
Thresholds
Threshold Description Value
VA Contract Value Ratio Ratio between a single VA Contract Value Amount and 25%
Brokerage Total Net Worth
Total Value Ratio Ratio between VA Contracts Total Value Amount and 50%
Brokerage Total Net Worth
Value Amount Attribute The method for calculating the Value Amount. The • Commitment
method can be: (default)
• Contract Amount Commitment - value Amount is equal • Balance
to the Account Commitment Size
• Balance Amount - value Amount is equal to the total of
all subaccount allocations (sum of all positions in VA
account)
Scoring
Score Factor Description Scoring Default
Scale Value
The ratio exceeds the The degree (%) that the ratio exceeds the threshold 0-5 20
threshold
5-10 40
>10 60
User-Defined Lists
Users can add the appropriate items to the user-defined lists using the options in the Lists tab of
the Actimize RCM.
Account Exclusion List Accounts that must be excluded from the analysis User defined
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 73
Detection Models
3.3.5.3 Flexibility
Business users can adjust the following settings using the options available in the RCM.
Thresholds
Threshold Name Threshold Description Default
Value
Brokerage Account Look Back Days to look back for buy and sell transactions in the 45
Period brokerage account
Ratio Net Sale of High Load Net of all purchases and sales in the brokerage account to 50%
Product to VA contract size VA contract size
Scoring
Name Description Score Scale Default
Value
VA contract size The monetary value of the VA contract 20,000-100,000 10
100,000-250,000 20
>250,000 30
PRODUCT CONFIDENTIAL
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Detection Models
User-Defined Lists
Users can add the appropriate items to the user-defined lists using the options in the Lists tab of
the Actimize RCM.
List Name Description Example Values
Account Exclusion List Accounts that must be excluded from the analysis User defined
PRODUCT CONFIDENTIAL
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Detection Models
5. Count the Number of Transactions (all mutual fund buys and sells) for the contract.
6. Sum the monetary Value of Total Transactions (mutual fund buys/sells) for the contract.
7. Sum the monetary Value of Buy Transactions (mutual fund buys) for the contract.
8. Sum monetary Value of Sell Transactions (mutual fund sells) for the contract during the
lookback period.
9. Determine the Total Buys/Sells Ratio = Value of Buy Transactions divided by the Value
of Sell Transactions.
10. Generate an alert if the Number of Total Transactions > the Minimum Number of
Transactions threshold for that period,
AND
The Value of Total Transactions > the Minimum Total Transactions Value threshold,
AND
The Total Buys/Sells Ratio > the Total Value of Buys and Sales Ratio threshold.
3.3.6.4 Flexibility
Business users can adjust the following settings using the options available in the RCM.
Thresholds
Threshold Name Description Default Value
The Lookback period (In Lookback period in days 90
days)
Aggregation Level (Fund, The detection aggregation level. The model can be set Fund_Family
Fund_Family, for one of the following:
Multi_Family)
• Fund – analysis for market timing within a specific
fund
• Fund_Family – analysis across all funds in a family
(default)
Multi_Family – analysis across families
Minimum Value of Total Determines thresholds for the value of transactions for $30,000
Transactions the lookback period
Minimum Ratio between Determines the threshold for the ratio of buys/ins over 75%
Buys/Ins and Sells/Outs sells/outs (%)
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Detection Models
Scoring
Score Factor Description Scoring Scale Default
Value
Degree of Score values assigned based on the percentage >10%-50% 10
Violation by which the number of transactions threshold
was violated. >50%-100% 20
The higher the percentage, the higher the score.
> 100% 25
>95% 25
Activity Value Score values assigned based on the total value $0-$100,000 5
of the transactions involved in the activity.
The higher the value, the higher score. >$100,000-$500,000 10
>$500,000 25
User-Defined Lists
Users can add the appropriate items to user-defined lists using the options in the List tab of the
Actimize RCM.
List Name Description Example
Values
VMT - Product Exclusion List Identifies specific products to be excluded User defined
VMT - Account Exclusion List Accounts that must be excluded from the analysis User defined
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Detection Models
3.3.7.1 Filters
Apply Account review filters
SPO Filters
• Exclude accounts according to “Account Exclude List”
• Exclude Account Key <> master account
• Exclude accounts that do not have Available Profile.
3.3.7.3 Calculations
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Detection Models
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Detection Models
Account’s Total Score values assigned The larger the Scale Score
Assets based on the total market order the higher
value of the securities and the score 10,000-100,000 5
cash positions within an
account. The higher the 100,000-500,000 10
value, the higher the score.
>500,000 15
20-30 1.15
30-40 1.2
40-50 1.25
50-60 1.5
60-70 2
>70 2.2
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Detection Models
Format: Number
Setting tree: threshold->SPO
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Detection Models
The following subsections provide information regarding each of the tabs that may appear.
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Detection Models
This section lists the Account Review models that generated issues that contributed to the
currently selected alert. Some issues can be expanded to display scenarios that were used by
the model during detection.
For each scenario in the expanded area, you can view the Current Value, the value that is being
analyzed, and the Check Value, which can be a threshold, a calculation or a setting. When
applicable, an issue is generated based on the comparison of values. For some of the scenarios,
a score is assigned based on the Current Value.
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Detection Models
The Brokerage Account Overall Risk, which appears at the top of this section, includes only
products that are not VA.
For VA products, there is partial information displayed at the position top level. You can expand
the section to view the breakdown of the VA contract. When the VA contract is a composite
product, you see its allocation. When the VA contract has a different position for each product,
these positions are presented under the VA contract.
1. Positions for the current account key.
Column Value
Product Type Position product type
MV Position MV
Total Portfolio Risk Impact Position MV / Total Risk Weighted Total Score
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Detection Models
Column Value
Product Type Position product type
Total Portfolio Risk Impact Total Composite Position MV /Total Risk Weighted Total
Score
Quantity “N/A”
Price “N/A”
% of Total Net Worth Total Composite Position MV/ Account net worth
Is composite product If Position composite product is null then ‘No’ else ‘Yes’
b. Nested table.
Column Value
SecuID – product_key Contract product
MV Composite product MV
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Detection Models
3.3.7.22 Transactions
The Transactions tab displays data regarding the transactions of the account for the current
month.
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Detection Models
• Prior Alerts by Broker – displays all prior Account Review alerts within a user defined
lookback period, associated with the trade’s broker (RR)
3.3.8.1 Filters
Apply Account review filters.
SPC Filters
• Exclude accounts according to “Account Exclude List”
• Exclude positions that Total quantity for position risk <=0
• Exclude accounts that do not have trades on the relevant business date (process date)
3.3.8.3 Calculations
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Detection Models
• Portfolio Concentrated Risk > (“Account Tolerance Factor“ threshold / 100) * Account
Tolerance to Risk
• Liquid Net Worth >= 0 OR Net Equity >=0
Name Description
Account Exclude List A list of accounts that need to be excluded from the detection
analysis.
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Detection Models
Format: Percent
Setting tree: Threshold -> SPC
Account Total High Score values assigned based on the The larger Scale Score
Risk Security total market value of the high-risk the order the
Position positions within an account. The higher higher the 10,000- 5
the value, the higher the score. score 100,000
100,000- 10
500,000
>500,000 15
Score values assigned based on the The larger Lower value Score
the order the
0 0.5
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Detection Models
25 2
30 2.5
40 3
>50 3.5
3.3.9.1 Filters
Exclude accounts that fulfill one of the following:
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Detection Models
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Detection Models
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Detection Models
3.3.9.12 Months from Previous SSC Focus Issue for this Account
The difference between the current month and Prev ACR alert (Issue Type).
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Detection Models
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Detection Models
Security Types Exclude List A list of product subtypes that need to be excluded from the detection
analysis.
High Yield Security Type List of security subtypes that are only excluded from the High Yield
Exclusion List Bond analysis
High Yield Security Exclusion List of Fixed Income securities that are only excluded from the High
List Yield Bond analysis
Complex Products List List of security types (Product Subtypes) that are considered ‘Complex
Products’ (Under FINRA, IOSCO and other global or bank specific
standards)
Calculation: None
Format: Number
Calculation: None
Format: Number
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Detection Models
Calculation: None
Format: Number
Regular Thresholds
Name Description Value
% Change in Overall Minimal % change in portfolio value from previous 30%
Portfolio Value for a concentration alert for this account. Determine if a
new issue new alert will be generated.
Thresholds > SSC
Calculation: None
Format: Number
Calculation: None
Format: Number
Calculation: None
Format: Number
Low Price ($) Threshold (Price < threshold) for determining whether Exchange Value
a security is low priced (Penny Stock). CD
Value should be decimal. Relevant only to Equities
Thresholds > SSC
All 5
Calculation: None
Format: Number
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Detection Models
The following are the default values of the Concentration Criteria Scores.
Factor Description General Rule Specific Rules
Sector vs. Net Score values assigned based on The larger the order Scale Score
Equity score the difference between the sector the higher the score
threshold and the section value 0-10 40
10-50 50
50-100 60
100-200 70
>200 80
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Detection Models
50-100 60
100-200 70
>200 80
1.5 25
2 30
2.5 35
Prior Alerts Previous Concentration alerts for the same Account Low Value Score
Threshold > ACR > General Threshold and Score
0 0
1 20
2 40
3 and up 60
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Detection Models
no economic rationale. Therefore, this model surveys these LTHL purchases and looks back a
predetermined period of time to determine if the purchase was funded by the sale of another
LTHL. Switches are identified by observing patterns as they emerge and flagging such behavior
for supervisory review.
To identify LTHL switching, the model creates two groups of trades:
• A triggering set of trades
• A set of trades of opposite side in a defined lookback period
If the difference between these groups is below a configurable percentage, the model generates
an alert.
General Filters
1. Exclude Fee Base Account.
2. Exclude trades marked as Free Exchange.
3. If Exclude Buy Trades with Zero Commission threshold = True, include only trades where
trade commission > 0.
4. Exclude trades that did not cause a new commission or CDSC filter.
5. Exclude system rebalanced trades.
Prelogic Filters
These are specific filters that are applied at the single trade level. The model’s logic will run on
the trade population after these filters are applied.
The following filters are applied at the single-trade level.
1. Apply general Daily Account Review filters.
2. Apply the general filters outlined above.
3. Retrieve trades that fulfil the following:
Sum of fees and commissions >= Minimum Trade Charge threshold.
4. Determine if trade exceed the Minimum Trade Value Calculation Mode setting.
If this setting is set to Minimum Trade Size, retrieve trades whose Trade net amount >=
Minimum Trade Size threshold.
If this setting is set to Minimum Trade % Size, retrieve trades whose Net Amount and
Account Net Equity % ratio >= Minimum Trade % Size threshold.
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Detection Models
• Lookback Group – a list of product subtypes defined in the RCM. Trades whose product
subtypes are included in this list are part of this. The trades are within the period defined by
the Buy Look Back Period threshold or Sell Look Back Period threshold.
• Scenario – a scenario is a pairing of an HSG group and a Lookback group. The number of
scenarios and the number of pairings is configurable. It is possible to add scenarios and
define the pairing logic.
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Detection Models
6. No value of any trade is used more than once per scenario in the model’s lifecycle.
7. The remaining sequence is used for the next day, prioritized by date and value.
The following are some examples.
Example 1: Previously Used Partial
HSG (Buy):
Trade 50,000
Trades in LBP (Sell):
• Trade 1 20,000 10:00
• Trade 2 25,000 10:01
• Trade 3 95,000 10:05
Sort by date and value:
• Trade 3
• Trade 2
• Trade 1
LBP Sum:
• Trade 3 50,000 Previously Used Partial
• Trade 3 45,000 Remaining Value; carry over for this scenario to tomorrow
Example 2: Previously Used Full
HSG (Buy): Trade 50,000
Trades in LBP (Sell):
• Trade 1 30,000 10:00
• Trade 2 20,000 10:01
• Trade 3 10,000 10:02
• Trade 4 20,000 10:03
Sort by date and value:
• Trade 1
• Trade 2
• Trade 4
• Trade 3
LBP Sum:
• Trade 1 30,000 -> Previously Used Full
• Trade 2 20,000 -> Previously Used Full
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Detection Models
3.3.10.5 Calculations
Fee-Based Account
Account that fulfills all the following conditions:
• Fee-Based Enroll Date ≠ NULL
• Fee-Based Enroll Date <= Current process date
• Account that fulfills one of the following conditions:
▪ Fee-Based Term Date is Null
▪ Fee-Based Term Date > current process date
Name Description
Hybrid Switching Group List of product subtypes used to identify trades that will be used as
triggering trades for the HSW logic.
Hybrid Switching Lookback List of product subtypes defined in the RCM. Trades whose product
Group subtypes are included in this list will be a part of the Lookback group. The
trades are within the period defined by the Buy Look Back Period
threshold or Sell Look Back Period threshold.
Hybrid Switching Scenarios A pairing of an HSG and a lookback group, each one on opposite sides
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Detection Models
Minimum Trade Value • Region Determines whether to use Minimum Min. trade
Calculation Mode Trade Size or Minimum Trade Size ($) size
• Product to filter transactions
subtype
Minimum Trade Size • Region Minimum size of the trade (currency) 2000
(Currency)
• Product
subtype
Minimum Trigger Size • Region Minimum size of the triggering set 2000
(Currency)
• Scenario NOTE:
Once you define the Hybrid Switching
Scenario for a specific Hybrid Switching
Group and Hybrid Switching Lookback
Group, you can then access this
threshold from the Hybrid Switching
Scenario defined for those groups (by
clicking Edit User Value).
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Detection Models
Switching Difference (%) • Region Difference (%) between the size of all 25
prior trades and the triggering trades
• Scenario
NOTE:
Once you define the Hybrid Switching
Scenario for a specific Hybrid Switching
Group and Hybrid Switching Lookback
Group, you can then access this
threshold from the Hybrid Switching
Scenario defined for those groups (by
clicking Edit User Value).
Exclude Buy Trades with System Exclude buy trades with zero True
Zero Commission commission (True / False)
Lookback Trade Elimination • Region This threshold affects the way the False
Option trades in the lookback period group are
• Scenario summed.
NOTE:
Once you define the Hybrid Switching
Scenario for a specific Hybrid Switching
Group and Hybrid Switching Lookback
Group, you can then access this
threshold from the Hybrid Switching
Scenario defined for those groups (by
clicking Edit User Value).
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Detection Models
21-50 5
51-64 10
65-75 15
>=76 20
Amount of Sales Score value assigned based on the amount of the 100-499 5
Charge sales charge incurred by the switch. The higher the
amount, the higher the score 500-999 10
Calculation:
>=1000 15
Max (avg (Sum of fees and commissions) of trades in
HSW group) of triggering scenarios
Switching Difference Difference (%) between the size of all prior trades 0-19 15
and the triggering trades.
Calculation: 20-29 10
Min (abs (Scenario Trigger Sum -Scenario Lookback 30-39 5
Sum)/ Scenario Trigger Sum) from all triggering
scenarios. >=40 0
Time between Trades Score value assigned based on the length of time 0 45
(Days) between today’s purchase and the prior sale, or on
today’s sale and the prior purchase. The lesser the 1 35
time, the higher the score.
11 25
Calculation:
Min (trigger date - last lookback period trade date) of
all triggering scenarios.
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Detection Models
LOI eligible
No Alert Alert
“NMB Option”
threshold for MMB
No Alert MMB No ROA eligible Yes
Yes
ROA Alert
No Alert MMB NMB
No Alert
Alert
“NMB Option”
Alert ROA NMB threshold for ROA
No Alert
3.3.11.1 Filters
The MFB model suite applies the following filters:
• Exclude product key in ‘MFB Security Exclude List’
• Exclude Account key ‘MFB Account Exclude List’
• Exclude Account household ‘MFB Household Exclude List’
• Exclude product fund family key ‘MFB Fund Family Exclude List’
• Exclude product sub type ‘MFB Security Subtype Exclusion List’
• Trade row update = process date
• Trade MF Sales Charge >= 0
• Product type ='MFU’
• In MMB or NMB for MMB: mutual fund shares = ‘A’ or mutual fund shares = null
• In MMB NMB for MMB: No Load Product = ‘FE’ or No Load Product = null
• The logic uses the logic of Cancel Correct Trades
MFB Trade
Trade that fulfills all the following conditions:
• Trade Access key = current Trade Access key
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Detection Models
• In LOI, MMB or NMB for MMB or from Calculations: MFB Trades Amount or MFB As of
Trades Amount: Product
• From Calculations: MFB As of Trades Amount or ROA As of Trades Amount Use Date(Trade
Date) = Process Date < Process Date otherwise use Date(Trade Date) = Process Date
Round by Precision
Round the number and save the digits after the decimal point. The number of digits after the
decimal point is based on the “Precision” threshold.
Example:
The number is 3.678, “Precision” threshold is 2 => 3.68
The number is 3.673, “Precision” threshold is 2 => 3.67
Example:
Accounts:
A2 H2
A3 H3
Products:
Product Consolidation Level
P1 Account
P2 Household
P3 Household
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Detection Models
Account A1 P2 H1
Account A1 P3 H1
Account A2 P1 A2
Account A2 P2 H1
Account A2 P3 H1
Account A3 P1 A3
Account A3 P2 H1
Account A3 P3 H1
Household A1 P1 A1
Household A1 P2 H1
Household A1 P3 H1
Household A2 P1 A2
Household A2 P2 H1
Household A2 P3 H1
Household A3 P1 A3
Household A3 P2 H1
Household A3 P3 H1
MFB Position
Position that fulfills all the following conditions:
• Position product type =’MFU’
• Position Date = current process date
• Position Access key = Account Access key
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Detection Models
As-of Trade
Process Date – Trade Date (different of days)
NOTE:
The MFB Filter Trade = Process Date.
Cancel trades
The logic filters:
• Cancelled trades
• Trades that were canceled in the current date (first trade, second trade):
▪ First trade date = current process date
▪ Second trade date = current process date
▪ First trade original key = Second trade original key
Correct trades
The logic uses the latest trade that was corrected:
• Scenario number 1: there is no Corrected trade – use the first new transaction
• Scenario number 2: there are couple of correct trade use the transactions with max(Trade
date)
3.3.11.3 Flexibility
Minimum Net Amount Minimum trade net amount that is considered in the $1000
logic
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Detection Models
MFB Security Exclusion List Securities that must be excluded from the analysis IBM
MFB Security Subtype Security subtypes that must be excluded from the GM (GNMA)
Exclusion List analysis TB (Treasury Bills)
MFB Fund Family Exclude Security subtypes that must be excluded from the
List analysis
Detection Logic
MMB
For each trade product key that fulfills all the following conditions:
• Date(Trade Date) = Process Date
• Trade Access key = current Account Access key
• (MFB Trades Fee * 100)/ MFB Trades amount - Product Break Point Percent) Round by
Precision >= ‘Minimum MMB MF Sales Charge Difference’ threshold Round by Precision
• Transaction Type is Buy
• MFB Trades amount >= ‘Minimum Net Amount threshold
NMB
For each trade product key that fulfills all the following conditions:
• Date(Trade Date) = Process Date
• Trade Access key = current Account Access key
• MFB Trades amount >= ‘Minimum Net Amount’ threshold
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Detection Models
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Detection Models
Flexibility
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Detection Models
Calculation: MFB Trades Fee round by precision * 100/ MFB Trades amount round by precision - Product
Break Point Percent round by precision
Example
A client buys $10,000 of a mutual fund, which would subject him to a high sales charge. But he
has signed an LOI pledging to buy a total of $100,000 over the next 13 months. He is charged
the lower sales charge rate immediately as if he had already purchased the full $100,000 today.
Filter
• Include MFB Trade
• Exclude Core System Rebalanced trades
Detection Logic
Account that fulfills all the following conditions:
• Account Letter of Intent is Valid
• (MFB Trades amount round by precision + MFB As of Trades Amount + LOI Position
Amount) > LOI commitment amount
• (((LOI Buy Trades sales charge round by precision *100) / MFB Trades amount round by
precision) - LOI Product Break Point Percent round by precision) >= ‘Minimum LOI MF Sales
Charge Difference’ threshold round by precision
• MFB Trades amount round by precision >= ‘Minimum Net Amount’ threshold
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Detection Models
Then all the Account LOI that have the current Account Household
Else Account LOI
Flexibility
LOI Thresholds
Threshold Name Description Default
Value
Minimum LOI MF Sales The minimum difference between the % charged and 0%
Charge Difference the expected LOI % charge required to qualify to be an
issue.
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Detection Models
LOI Scoring
Score Factor Description Scoring Scale Default
Value
Letter of Score values assigned when an incorrect discount is <3% 10
Intent (LOI) received with a signed LOI.
Scoring scale is according to the % amount of
discount lost. 3% 20
Calculation: (LOI Buy Trades sales charge *100)/ MFB Trades amount) Round by Precision - LOI
Product Break Point Percent
Display
• Issue Type: “Letter of Intent”
• Description: “A transaction did not receive a proper discount as per the LOI. (Fee paid:”+
LOI Buy Trades sales charge round by precision + “, Fee with LOI commitment:” + LOI
Breakpoint Sales Load Percent“)”
• Score: Total Scenario Score
▪ Scenario: “Letter of Intent”
Description: “A transaction did not receive a proper discount as per the LOI. (Fee
paid:”+ LOI Buy Trades sales charge round by precision + “, Fee with LOI
commitment:” LOI Product Break Point Percent round by precision + “)”
Current Value: (LOI Buy Trades sales charge round by precision / (MFB Trades
amount round by precision*100) - LOI Product Break Point Percent round by
precision
Format: Amount
Check Value: ‘Minimum LOI MF Sales Charge Difference’ threshold round by
precision
Format: Amount
Score: ‘Letter of Intent (LOI)‘ score
Example
A front-end mutual fund purchase occurs in a customer account that has other prior purchases
for that fund family, and a check is done to ensure that the client received the lowest possible
sales charge, which is earned under the fund’s ROA parameters.
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Detection Models
Detection Logic
ROA
For each trade product key that fulfills all the following conditions:
• Date(Trade Date) = Process Date
• ROA Eligible = “Yes”
• MFB As of Trades Amount + MFB Trades Amount >= ‘Minimum Net Amount’ threshold
• Fulfill one of the following:
▪ If “MFB Account or Household” threshold = “Account” and ROA Product Level = “Fund”
Then Account/Fund ROA Method
▪ If “MFB Account or Household” threshold = “Account” and ROA Product Level =
“FundFamily”
Then Account/Family ROA Method
▪ If “MFB Account or Household” threshold = “Household” and ROA Consolidation Level =
null or “Household” and ROA Product Level = “Fund”
Then Household/Fund ROA Method
▪ If “MFB Account or Household” threshold = “Household” and ROA Consolidation Level =
null or “Household” and ROA Product Level = ”FundFamily”
Then Household/Family ROA Method
▪ If “MFB Account or Household” threshold = “Household” and ROA Consolidation Level =
“Account” and ROA Product Level = “Fund”
Then Account/Fund ROA Method
▪ If “MFB Account or Household” threshold = “Household” and ROA Consolidation Level =
“Account” and ROA Product Level = “FundFamily”
Then Account/Family ROA Method
NMB
For each trade product key that fulfills all the following conditions:
• Date (Trade Date) = Process Date
• Position Access key = current Account Access key
• If ‘NMB Option’ threshold for ROA = “On”
• MFB As of Trades Amount + MFB Trades Amount >= ‘Minimum Net Amount’ threshold
• No ROA Alert:
▪ (ROA Buy Trades sales charge* 100)/ Product/Family Amount – ROA Product Break
Point Percent) Round by Precision < ‘Minimum ROA MF Sales Charge Difference’
threshold round by precision
▪ (ROA Buy Trades sales charge* 100/ Product/Family Amount – ROA Product Break Point
Percent) Round by Precision >= ‘Minimum NMB MF Sales Charge Difference’ threshold
Round by Precision
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Detection Models
• NMB Eligibility %
▪ If ‘NMB Method – Percentage’ threshold = “On”
Then (100 - ROA Near break point* 100) Round by Precision < ‘NMB Eligibility %’
threshold
Else True
• NMB Eligibility $ Value
▪ If ‘NMB Method - Dollar Value’ threshold = “On”
Then
ROA Last Break Point is not null
AND
(ROA Last Break Point – Product/Family Amount) Round by Precision < ‘NMB Eligibility $
Value’ threshold
Else True
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Detection Models
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Detection Models
Then 0
Else (Product/Family Amount) / ROA Last Break point
Product/Family Amount
ROA As of Trades Amount + ROA Position Amount + ROA Trades amount
Flexibility
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Detection Models
Calculation:
ROA Buy Trades sales charge*100/ Product/Family Amount - ROA Product Break Point
Percent
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Detection Models
3.3.12.1 Filters
For the Include List model, the general Daily Account Review filters apply, including the following:
• Exclude proprietary accounts
• Exclude non-customer accounts
• Exclude Account key that is in the “Account Exclude List”
• Exclude accounts that do not have trades on the relevant business date (process date)
The account include list in this model overrides these lists. This means that even if an account is
excluded by the general Daily Account Review filters, if it is in the model, the include list account
will be included in the alert.
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Detection Models
3.3.12.3 Calculations
The Last Balance Date available is calculated from the database.
Net Equity
The Net Equity for the Last Balance Date available is received.
Total Balance Value that fulfills the following:
▪ Balance Date = Last Balance Date
▪ Balance Account = Current Account
▪ Balance type is net equity
Example
For sample Security List XYZ:
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Detection Models
Passed the
Monitoring End
date of the
3/25/2014 ABC999888 13,500 Yes account
3.3.12.4 Flexibility
Scoring
Factor Description Value
Include List This score is added if this 20
scenario is detected. The Score
is at List level (for example, List A
issues have a score of 20; List B
issues have a score of 50, and so
on).
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Detection Models
Calculation: None
User-Defined Lists
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Daily Account Review Details Screens
• Expiration Date – the date after which the securities are not included for generating an alert
(monitoring end date). The default is no end date.
• User Defined Lists
Name Description Example Values
Included Transaction The transactions types that must be Possible values:
Types - <list name> included in the analysis. In the display
• Buy
just the descriptions will be shown.
• Sell
• Buy to Cover
• Short Sell
• Sell to Close
• Sell to Open
• Buy to Open
• Buy to Close
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Daily Account Review Details Screens
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Daily Account Review Details Screens
For each scenario within the expanded area, you can view the Current Value (the value being
analyzed) and the Check Value (a threshold, a calculation or a setting). When applicable, an
issue is generated based on the comparison of values. For some of the scenarios, a score is
assigned based on the Current Value.
The Score Information section shows an additional score based on previous alerts on the same
account. It includes a factor called Previous Alerts with a Value column, displaying the number
of prior alerts per account, and a Score column, displaying a score value based on the number of
prior alerts. The more Previous Alerts the higher the score.
The score value displayed refers to the number of prior alerts in the last set number of months.
The period of the prior alert is configurable by threshold. The default value for DAR is 10 months.
The default value for ACR and TRR is 6 months.
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Daily Account Review Details Screens
• Period Summary - the information in the Period Summary section is based on the defined
aggregation level (Fund, Fund Family or Multifund family). The aggregation summary
information and the user-defined threshold value (shown within brackets) appear for the
lookback period.
• Potential Mutual Fund Market Timing Activity – shows all mutual fund transactions sorted
by aggregation level.
• Period Summary – the information contained in this section is for each contract, and is
based on the defined aggregation level (Fund, Fund Family or Multifund family). The
aggregation summary information and the user-defined threshold value (shown within
brackets) appear for the lookback period.
• Potential Mutual Fund Market Timing Activity – shows all variable annuity mutual fund
transactions sorted by aggregation level.
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Daily Account Review Details Screens
3.4.4.7 Portfolio
The Portfolio tab provides a list of investment holdings, including the total overall risks.
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Daily Account Review Details Screens
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Daily Account Review Details Screens
• Prior Alerts by Broker – shows all prior Daily Account Review alerts, within a user defined
lookback period, associated with the account broker (RR)
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Chapter 4: Trade Review (TRR) Model Groups
4.1 Overview
The Actimize SP Trade Review (TRR) models include a group of analytical models developed for
the primary purpose of identifying trades that may require additional supervisory review.
This model group is an integral part of the Trade Blotter Report, providing convenient access to
in-depth compliance surveillance of all blotter transactions. It is also accessible directly from the
Actimize Risk Case Manager.
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Overview
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Overview
B & C Share Analysis This model identifies potential mutual fund investment activity that
(TRR-BAC) may result in an economic disadvantage for the customer when they
purchased B or C class shares. If positions in class B, C, and/or
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Trade Review General Attributes and Conditions
4.2.1 Frequency
The Trade Review models are all designed to run on a daily basis (T+1).
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Trade Review General Attributes and Conditions
PRODUCT CONFIDENTIAL
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Detection Models
Thresholds
Threshold Name Description Default
Value
Alert Max Score Maximum alert score value to which the final alert score 100
is compared
Lookback Period for Prior Alerts A general Trade Review threshold that sets the period 6 months
used when counting prior historical alerts.
Number of days trades Determines the expected maximum latency for a trade. 0
registration is being delayed Latency refers to the period between the Trade Review
process date and the Trade Date. If higher latency is
identified, trade is flagged as a delayed trade (As of
Trade).
Scoring
The following general scoring factors are applied to all trades in the process of alert generation
by the ASF rule. By default, this rule is activated.
Factor Description Scoring Default
Scale Value
Additional Scoring Score value assigned by account based on alert 1-5 10
(ASF) - Prior Alerts by history.
Account The same alert type during the last 6 months, 5-10 20
including all today’s alerts.
>10 30
The more past alerts, the higher the score.
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Detection Models
4.3.1.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring
Score Factor Description Default Value
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Detection Models
4.3.2.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring
Score Factor Description Default Value
Off-Hours Trade score Score value assigned if trade occurred during off hours 20
4.3.3.4 Flexibility
Business users can adjust the following settings using the options in the Actimize RCM.
Thresholds
Threshold Name Description Default Value
Maximum Time Period to Maximum allowed time period (in days) before the 30
Expiration option’s imminent expiration date
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Detection Models
Scoring
Score Factor Description Default Value
Time to Expiration < Score value assigned if time to expiration is less than 20
Threshold the value assigned for the Maximum time Period to
Expiration threshold
Buy to Open
Sell to Open
NOTE:
Transaction types are mapped during the implementation stage of deployment (see Section
4.2.5: Transaction Types, page 136).
OR
Absolute Net Amount > Maximum Allowed Trade Net Amount calculated threshold.
c. If Trade Variance Check Setting is set to Maximum Allowed % of Trade Net Amount,
generate an alert if the Security Risk Variance > the calculated Account Tolerance to Risk
threshold;
OR
Trade Net Amount Ratio (Percent) > Maximum Allowed % of Trade Net Amount
calculated threshold.
d. If Trade Variance Check Setting is set to Maximum Allowed % of Trade Net Amount Age
Based, generate an alert if the Security Risk Variance > the calculated Account Tolerance
to Risk threshold;
OR
Trade Net Amount Ratio (Percent) > Maximum Allowed % of Trade Net Amount Age
Based calculated threshold.
4.3.4.4 Flexibility
Business users can adjust the following settings with the options available in the Actimize RCM.
Settings
Setting Name Description Default
Value
Set default risk Sets whether or not to use the Default Risk Value for Security 1 (Yes)
Risk Variance. When the calculation value for Security Risk
Variance is null then:
• If set to Yes, use the Default Risk Value defined in the
threshold Default Risk Value located in Thresholds > SP
General > Product Risk.
• If set to No, then the Security Risk Variance value should be
set to 0 and no alert is generated.
Absolute Net Amount Setting for activating the scenario: Absolute Net Amount. If No is 1 (Yes)
Check (Y/N) used, the model does not use this scenario during analysis.
Also known as Absolute Net Amount
Trade Variance This setting determines the logic used during model detection: Maximum
Check Setting Allowed % of
• None
Trade Net
• Absolute Net Amount Amount
• Maximum Allowed % of Trade Net Amount (Variance)
• Maximum Allowed % of Trade Net Amount Age Based
(variance by age)
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Detection Models
Thresholds
NOTE:
Thresholds used for Detailed Calculations for Security Risk are provided in Chapter 7: Risk-
Related Calculations, page 202.
3-4 60%
4+ 75%
Maximum Allowed Trade Net Determines the threshold values for the 0-1 $100,000
Amount maximum allowed net amount.
This threshold is displayed only when 1-2 $300,000
Absolute Net Amount is set to Yes.
2-3 $500,000
The default value depends on the Account
Risk Tolerance. 3-4 $700,000
4+ $1,000,000
Minimum Trade Net Amount Determines the threshold value for the $500 Minimum
minimum net amount of interest Trade Net
Amount
Minimum Account Net Equity Determines the threshold value for the $100,000 Minimum
minimum account net equity Account Net
Equity
Maximum Allowed % of Determines the threshold values for the 0-20 10%
Trade Net Amount - Age maximum allowed percent of trade amount
Based out of the larger of Account Net Equity or 21-50 50%
Liquid Net Worth.
51-59 30%
The default value depends on the Age
Risk Factor. 60-75 20%
>76 10%
NOTE:
The Security Risk Variance calculation is based on thresholds that are defined Chapter 7: Risk-
Related Calculations, page 202.
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Detection Models
40-59% 40
60-79% 60
80-99% 80
100% 100
Trade Net % Variance Score value assigned based on variance between 0-10% 0
Allowable Trade Net % and Trade Net as a % of the
higher of Liquid Net Worth or Account Net Equity 10-25% 10
The higher the percentage above the threshold
26-39% 20
level, the greater the score.
40-59% 40
60-79% 60
80% 80
User-Defined Lists
Users can add the appropriate items to the user-defined lists using options in the List tab of the
Actimize RCM.
Security SubTypes Security subtypes that must be excluded from the GM (GNMA),
Exclusion List analysis TB (Treas. Bills)
Security Exclusion List Securities that must be excluded from the analysis IBM
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Detection Models
4.3.5.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Thresholds
Threshold Name Description Default Value
Low Price Determines the threshold value for the maximum allowed $5.00
share price
User-Defined Lists
Users can add the appropriate items to the user-defined lists using options in the List tab of the
Actimize RCM.
List Name Description Values
LST Exchange Exclusion Exchanges that must be excluded from the analysis Sample values:
List NYSE
AMEX
NMS
LST Securities Exclusion Securities that must be excluded from the analysis Sample values:
List GM (GNMA)
TB (Treas. Bills)
Scoring
Score Factor Description Default Value
Low Price Security Trade Score value assigned when price/weighted average 20
per share < Low Price Threshold
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Detection Models
NOTE:
Transaction Types are mapped during the implementation stage of deployment (see Section
4.2.5: Transaction Types, page 136).
4.3.6.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
HYB Security Subtype Security subtypes that must be excluded from the US Treasuries,
Exclusion List analysis Municipalities
HYB Security Exclusion Securities that must be excluded from the analysis GM (GNMA), TB
List (Treas. Bills)
S&P AA+ 1 Y
S&P AA 1 Y
S&P AA- 1 Y
S&P A+ 2 Y
S&P A 2 Y
S&P A- 2 Y
S&P BBB+ 2 Y
S&P BBB 2 Y
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Detection Models
S&P BB+ 3 N
S&P BB 3 N
S&P BB- 4 N
S&P B+ 4 N
S&P B 4 N
S&P B- 4 N
S&P CCC+ 5 N
S&P CCC 5 N
S&P CCC- 5 N
S&P CC+ 5 N
S&P CC 5 N
S&P CC- 6 N
S&P C+ 6 N
S&P C 6 N
S&P C- 6 N
S&P D 7 N
Moody Aaa 1 Y
Moody Aa1 1 Y
Moody Aa2 1 Y
Moody Aa3 1 Y
Moody A1 2 Y
Moody A2 2 Y
Moody A3 2 Y
Moody Baa1 2 Y
Moody Baa2 2 Y
Moody Baa3 2 Y
Moody Ba1 3 N
Moody Ba2 3 N
Moody Ba3 5 N
Moody B1 5 N
Moody B2 5 N
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Detection Models
Moody Caa1 6 N
Moody Caa2 6 N
Moody Caa3 6 N
Moody Ca 7 N
Moody C 7 N
InHouse A1 1 Y
InHouse A2 2 Y
InHouse B1 3 N
InHouse B2 4 N
Scoring
Score Factor Description Default
Value
High Yield Bonds - Existing Score value assigned if the alert is generated because 20
rates are below investment existing rates are below investment grades
grade
High Yield Bond Score - No Score value assigned if the alert is generated because no 10
rating exists rating exists
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Detection Models
• If the threshold Detect Large Trades for Buy Only or for Both Buy and Sell = Sell, then the
Current Trade Type is should include one of the following (using the mapping in Settings >
References in the RCM):
▪ SELL
▪ SELL TO OPEN
• If the threshold Detect Large Trades for Buy Only or Both Buy and Sell = Buy/Sell, then the
Current Trade Type should include one of the following (using the mapping in Settings >
References in the RCM):
▪ BUY
▪ SHORT SELL
▪ SELL
▪ SELL TO OPEN
▪ BUY TO OPEN
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Detection Models
Scenario 1:
Round by precision ABS (trade quantity) > round by precision Option Trades -
Maximum Allowed Quantity Threshold Value
OR
Scenario 2:
Round by precision ABS (trade principal amount) > round by precision Option
Trades - Maximum Allowed Principal Threshold Value
▪ For mutual fund:
If the security sub type is Mutual Fund switches:
Then round by precision ABS (trade principal amount) > round by precision
Security Subtype is Mutual Fund switches - Maximum Allowed Principal Threshold
Value
If the security subtype is Money Market:
Then round by precision ABS (trade principal amount) > round by precision
Security Subtype is Money Market - Maximum Allowed Principal Threshold Value
Otherwise:
Round by precision ABS (trade principal amount) > round by precision Mutual
Fund - Maximum Allowed Principal Threshold Value
4.3.7.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Thresholds
Threshold Name Threshold Description Default Value
Detect Large Trades for Buy Detects large trades for buy transactions only • Buy/Sell (default)
Only or for Both Buy and Sell or for both buy and sell transactions; options:
• Buy
• Buy/Sell
• Sell
OR
• Buy/Short Sell
Equity Trades - Maximum Maximum net amount allowed $50,000
Allowed Principal Threshold
Value
Fixed Income Trades - Maximum fixed income principal value allowed 100,000 (default for
Maximum Allowed Principal separated by product subtype (see the list of all security subtypes)
Threshold Value security subtypes in the following section).
Fixed Income Trades - Maximum number of units allowed separated 100 (default for all
Maximum Allowed Quantity by product subtype (see the list of security security subtypes)
Threshold Value subtypes in the following section).
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Detection Models
Security sub type is Mutual Maximum principal amount allowed when the $300,000
Fund switches - Maximum security subtype is Mutual Fund Switches
Allowed Principal Threshold
Value
Security sub type is Money Maximum principal amount allowed when the $300,000
Market - Maximum Allowed security subtype is Money Market
Principal Threshold Value
Security Subtypes
Security subtypes are defined in the RCM Settings > References > SP General > Mapping >
Security Sub Types. The following are the default values.
AD Agencies Discount
AG Agencies
AP Agency Pass-Through
BA Banker's Acceptance
BB Bonds Borrowed
BF Bond Futures
CAP Cap
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Detection Models
CN Corporate Note
CP Commercial Paper
EM Emerging Markets
FB Foreign Bonds
FM Freddie Mac
FR Repo
GB Governmental Bond
GLT Gilt
GM GNMA/ FNMA
HY High Yield
OB Other Bond
PP Private Pass-through
RS Return Swaps
SC Structured Credit
SF Structured Fund
SH Structured Hybrid
SL Sallie Mae
TB T-Bill
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Detection Models
TN T-Note
TRE Treasuries
User-Defined Lists
Users can add the appropriate items to the following lists using the options in the List tab of the
Actimize RCM.
Name Description Example Values
LTR Security Exclusion Securities that must be excluded from the analysis IBM
List
LTR Security Subtype Security subtypes that must be excluded from the GM (GNMA)
Exclusion List analysis TB (Treas. Bills)
LTR Account Type Account types that must be excluded from the HF (Hedge Fund)
Exclusion List analysis MU (Municipality)
Scoring
Score Factor Description Default Value
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Detection Models
4.3.8.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring
Score Factor Description Default Value
4.3.9.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring Scales
Score Factor Description Default Value
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Detection Models
4.3.10.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring Scales
Score Factor Description Default Value
Not RR of Record Score assigned when the RR assigned to the account is not 20
the trade’s RR.
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Detection Models
4.3.11.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Thresholds
Threshold Name Threshold Description Default
Value
Buy Look Back Period Days in lookback period when trigger transaction is a buy 30
Sale Look Back Period Days in lookback period when trigger transaction is a sale 5
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Detection Models
Minimum Trade % Size Minimum size of the trade as percentage of account net equity 20%
Switching Difference Difference (%) between the size of all prior trades and 25
triggering trades
Minimum Trade Value Determines which trades are excluded by the system; if setting Minimum
Calculation Mode is set to Minimum Trade Size, then this value is used to trade size
determine which trades are included in the review.
If setting is set to Minimum Trade % Size, then this value is
used to determine which trades are included in the review.
Aggregation Level Check for trades with the same account (=1) or the same 1
(Account or Household account household ID (=0)
ID)
Exclude buy trades with Exclude buy trades with zero commission (True / False) True
zero commission
NOTE:
Threshold displayed modes are dependent on the calculation basis in use.
User-Defined Lists
Name Description Example Values
Account Types Account types that must be excluded from the Company
Exclusion List analysis Bank
Broker
Individual
Account Subtypes Account types that must be excluded from the Margin
Exclusion List analysis Prop trading
Error
Scoring
Name Description Score Scale Default
Value
Time between Score value assigned based on the length of time Same day 45
trades (in days) between today’s purchase and the prior sale, or on
today’s sale and the prior purchase. The lesser the 1 – 10 35
time, the higher the score.
11 – 30 25
65 – 75 15
76 20
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Detection Models
> 1000 15
Switching Difference (%) between the size of all prior trades 0%-20% 15
Difference and triggering trades.
20%-30% 10
30%- 40% 5
>40% 0
4.3.12.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring
Score Factor Description Default Value
Solicited Trade Score Score value assigned if the trade is marked as solicited 20
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Detection Models
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Detection Models
Historical Look back Amount of time (in days) to look for additional 90
purchases
Amount or Value Percent of Ratio between amount or value and the next breakpoint 90%
Next Breakpoint
Example 1
A client purchased $60,000 of XYZ income fund or a combination of $30,000 of XYZ income fund
and $30,000 of XYZ growth fund.
The XYZ family of funds has a $50,000 breakpoint where the charge is reduced from 5% to 4%.
The firm charged this customer $3,000 in a sales load. An alert is issued because the sales load
should have been $2,400 - 4%, not 5%.
Example 2
Sixty days ago, a client purchased $30,000 of a front load mutual fund and paid a sales charge of
5% ($1500), the rate for purchases up to $50,000 according to the breakpoint schedule.
Today, the client purchased another $30,000 for a total of $60,000 in the same fund family.
After checking, it is determined that the client does not have an executed LOI on file, which would
entitle the customer to the new lower sales charge on all prior purchases done within the
lookback period. The client purchased $60,000 within the lookback period and has achieved the
lower breakpoint of 4% for purchases between $50,000 and $100,000. The client paid $1,200 for
today’s trade but this lower rate applies to ALL purchases in the lookback period.
Therefore, the client is entitled to a 4% rate on the initial purchase. For the trade of 60 days ago,
the client received a refund of $30,000 * (5% - 4%) or $300; this $300 is deducted from the fees
charged for the current trade so the client would pay $900 for the second purchase ($1,200 fee
for the current trade – $300 refund from the earlier trade). If more than $900 is charged, an alert
is issued.
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Detection Models
Detection Logic
1. Apply general Trade Review filters.
2. Apply all Mutual Fund breakpoint filters.
3. Apply MMB models-specific filters.
4. Determine the sum of the Total Net Amount and the Total MF Sales Charge Amount for all
MF Historical trades of the same Mutual Fund Family, over the MFB Historical Look Back
Threshold based on a user-defined Aggregation Level Setting (Account or Household ID).
5. If a valid signed LOI is on record, it will be checked by the LOI model and, therefore, end
analysis and proceed to the next trade.
6. If no LOI is on record or it has expired, determine the Breakpoint Sales Load Percent
based on the (Total Net Amount + Trade Net Amount) and the Trade Product ID, using
the Mutual Fund Sales Charge Breakpoint Schedules.
7. Calculate Entitled Sale Charge Amount = Breakpoint Sales Load Percent multiplied by (Total
Net Amount + Trade Net Amount).
8. Generate an alert if:
(Total MF Sales Charge Amount + Trade MF Sales Charge) > Entitled Sales Charge Amount
and (Total MF Sales Charge Amount + Trade MF Sales Charge) >Minimum Trade MF Sales
Charge Difference Threshold
OR
Near Breakpoint scenario has occurred according to the Near Breakpoint model Logic (see
Section 4.3.13.8: Near Breakpoint (NMB), page 163).
9. In the Alert Details, display the entitled refund for each historical trade = MF Sales Charge
Amount – (Breakpoint Sales Load Percent multiplied by Trade Net Amount).
Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring
Score Factor Description Aggregation Default
Level Value
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Detection Models
Example
A client buys $10,000 of a mutual fund, which would subject him to a high sales charge. But he
has signed an LOI pledging to buy a total of $100,000 over the next 13 months. He is charged
the lower sales charge rate immediately as if he had already purchased the full $100,000 today.
Detection Logic
1. Apply general Trade Review filters.
2. Apply all Mutual Fund breakpoint filters.
3. Determine if a valid signed LOI is on record based on Account and Mutual Fund Family.
4. If there is an LOI on record, then determine Breakpoint Sales Load Percent based on the
LOI commitment Amount and Trade Product ID, using the mutual fund Sales Charge
Breakpoint Schedules.
5. Calculate Entitled Sale Charge Amount = Breakpoint Sales Load Percent multiplied by Trade
Net Amount.
6. Generate an alert if Trade MF Sales Charge > Entitled Sale Charge Amount.
Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring Scales
Score Factor Description Scoring Scale Default
Value
$100-$999.99 10
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Detection Models
Example
A front-end mutual fund purchase occurs in a customer account that has other prior purchases
for that fund family, and a check is done to ensure that the client received the lowest possible
sales charge, which is earned under the fund’s ROA parameters.
Detection Logic
1. Apply general Trade Review filters.
2. Apply all mutual fund breakpoint filters.
3. Determine the sum of the previous Total Position Value (the opening position for the date of
analysis which is the closing position of the previous day) according to a user-defined
Aggregation Level Setting (Account or Household ID).
4. Determine Breakpoint Sales Load Percent based on the (Total Position Value + Trade
Net Amount) and the Trade Product ID, using the Mutual Fund Sales Charge breakpoint
schedules. Include positions for classes A, B and C of shares for all mutual funds that belong
to this family.
5. Calculate Entitled Sale Charge Amount = Breakpoint Sales Load Percent multiplied by Trade
Net Amount.
6. Generate an alert if:
▪ Trade MF Sales Charge > Entitled Sale Charge Amount
OR
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Detection Models
▪ A near breakpoint scenario has occurred according to the near breakpoint model logic
(see Section 4.3.13.8: Near Breakpoint (NMB), page 163)
Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring Scales
Score Factor Description Score Scale Default
Value
Rights of Customer paid higher fees than available $100-$999.99 10
Accumulation (ROA) under the fund’s ROA.
The greater the monetary amount, the higher $1,000 20
the score.
Example
A client purchased $35,000 in a mutual fund family over the previous 90 days and today
purchased an additional $12,000, reaching $47,000 in purchases during the breakpoint eligible
period. The next breakpoint is $50,000 and the client just missed this breakpoint. As $47,000 /
$50,000 represents 94% of the next breakpoint, an alert is raised.
Detection Logic
NOTE:
The NMB Logic is added to the MMB and the ROA models.
PRODUCT CONFIDENTIAL
Actimize Sales Practices (SP) and Suitability Solution Guide Page 163
Detection Models
1. Identify the Next Breakpoint Sales Load Schedule based on the Total Net Amount or
Value using the mutual fund sales charge breakpoint schedules.
2. Calculate the Breakpoint Sales Schedule Ratio = the Total Net Amount or Value divided by
the lowest amount in the Next Breakpoint Sales Load Schedule (the From amount).
3. Generate an alert if Breakpoint Sales Schedule Ratio > Current Amount Percent Of Next
Breakpoint Threshold.
4. In the alert, display the Next Breakpoint Sales Load Schedule.
Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring Scales
Score Factor Description Score Scale Default
Value
Near Score value assigned when customer purchases fall short 90-94.99% 5
Breakpoint of the amount required to take advantage of breakpoint
discounts. 95-99.99% 10
The near breakpoint ratio is the amount or value purchased
over the nearest breakpoint value.
Example
A client purchased $25,000 of a mutual fund with an investment objective of ‘capital
preservation’. The client also holds $25,000 of a second company’s capital preservation fund and
$75,000 from a third company’s capital preservation fund. If the total amount of different mutual
fund family purchases with the same investment objective exceeds X ($25,000 or $50,000) and
the fees paid individually exceed the fee that would have been charged by purchasing the full
amount in the current fund, then an alert is issued.
Detection Logic
1. Apply all Trade Review filters.
2. Apply all mutual fund breakpoint filters.
3. Retrieve all previous positions (the opening position for the date of analysis which is the
closing position of the previous day) according to a user-defined Aggregation Level Setting
(Account or Household ID) grouped by Fund Family.
4. Take Fund Family Positions Group = all Fund Family Positions that have a different fund
family than the trade product fund family and the group has at least one product in it with the
same Investment Objective as the Trade Product Investment Objective.
5. Determine the sum of the selected Fund Family Positions Group Value.
6. For each Mutual Fund Family Group, determine Breakpoint Sales Load Percent based on the
(Fund Family Positions Group Value + Trade Net Amount).
7. Choose the product with the Lowest Load Percent in the Mutual Fund Family Group that has
the same investment objective as the Trade Product using the Mutual Fund Sales Charge
Breakpoint Schedules.
8. Calculate Entitled Sale Charge Amount = Lowest Fund Family Breakpoint Sales Load
Percent multiplied by Trade Net Amount.
9. Generate an alert if Trade MF Sales Charge > Entitled Sale Charge Amount.
Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring
Score Factor Description Score Scales Default
Value
Multi-Fund Family Score assigned based on amount of discount lost by $1-$100 5
Purchases buying in a different fund family.
The greater the dollar amount, the higher the score. $100-$999.99 10
$1,000 20
Thresholds
This model uses only general thresholds and settings.
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Detection Models
Detection Logic
1. Apply general Trade Review filters.
2. Apply model-specific population filters.
3. Generate an alert if based on a user-defined Aggregation Level Setting (Account or
Household ID):
There is a trade in mutual fund shares other than class “A”
AND
Trade net amount equals or is greater than the Minimum Net Amount threshold
AND
IF the B Class Holding share total, aggregated across all mutual fund families, is above
threshold
OR
IF the C Class Holding share total, aggregated across all mutual fund families, is above
threshold
OR
IF the Other Class Holding shares total (with the exception of A), aggregated across all
mutual fund families, is above threshold,
OR
IF the Combined Holding for all classes shares total (A, B, C and other), aggregated
across all mutual fund families, is above threshold,
Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring Scales
Score Factor Description Default
Value
B, C shares analysis Score assigned when holding in B, C or other class of 20
shares is above threshold
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Detection Models
B class Holding Total holding in this class of shares aggregated across $95,000
multiple fund families
C class Holding Total holding in this class of shares aggregated across $95,000
multiple fund families
Other class Holding Total holding in this class of shares aggregated across $95,000
multiple fund families
Combined Holdings for all Total holding all classes of shares aggregated across $245,000
classes multiple fund families
Aggregation Level
This model is based on account-level or household level aggregation.
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Detection Models
4.3.14.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring Scales
Score Factor Description Default
Value
Blue Sky of Score assigned when security is not registered in a particular state. 20
Security
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Detection Models
4.3.15.4 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Settings
Threshold Name Description Default Values For Product Sub Type
VA Variable Annuities
Thresholds
Threshold Name Description Value
Use Account’s State Define whether to check the account’s state as a part of the Yes
Flag General License
Scoring Scales
Score Factor Description Default Value
Financial Consultant Score assigned when either security or broker did not pass the 20
Qualifications state and security qualifications
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Detection Models
4.3.16.3 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring
Score Factor Description Default
Value
Principal Trade in Score assigned when there is principal trade in a managed 20
managed account account
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Detection Models
4.3.17.3 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
Scoring
Score Factor Description Default
Value
High risk trade in managed or Score assigned when there is a high-risk trade in a 20
discretionary account. managed account
Thresholds
Threshold Name Description Initial Value
Maximum Allowed Principal Beta for Stocks Risk rating for equity 3.5
Maximum Allowed Moody’s rating for bonds Risk rating for bonds Baa1
Maximum Allowed S&P rating for bonds Risk rating for bonds BBB
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Detection Models
▪ If Principal Amount >= ”Large Trade Size” threshold according to product sub-type:
(100*Trade Commission / Principal amount) > “Maximum Large Trade Cost” threshold
according to product sub-type
• If “Measurement Options” threshold = “Fees”:
▪ If Principal Amount < ”Large Trade Size” threshold according to product sub-type:
(100*Trade Fees / Principal amount) > “Maximum Standard Trade Cost” threshold
according to product sub-type
▪ If Principal Amount >= ”Large Trade Size” threshold according to product sub-type:
(100*Trade Fees / Principal amount) > “Maximum Large Trade Cost” threshold according
to product sub-type
• If “Measurement Options” threshold = “Total Cost”:
▪ If Principal Amount < ”Large Trade Size” threshold according to product sub-type:
100*(Trade Commission + Trade Fees) / Principal amount > “Maximum Standard Trade
Cost” threshold according to product sub-type
▪ If Principal Amount >=” Large Trade Size” threshold according to product sub-type:
100*(Trade Commission + Trade Fees) / Principal amount > “Maximum Large Trade
Cost” threshold according to product sub-type
4.3.18.3 Flexibility
Business users can adjust the following settings using the options in the Actimize RCM.
Scoring
Score Factor Description Default Value
Percentage in excess of The percentage of the addition that was added to the Lower Score
expected expected cost value
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Detection Models
Cost/Commission/Total 0 5
Cost
5 10
10 15
20 20
Thresholds
Location: Thresholds SP Trade Review CTR – Cost to Trade Ratio
Minimum Principal The minimum principal amount of the account in order 500
Amount to add into the detection
Maximum Standard Trade according to product sub type according to the list This 5 (Defaults may
Cost list is defined in Reference SP General Mapping be established
Security sub type Code for each sub-
type)
Maximum Large Trade according to product sub type according to the list This 5 (Defaults may
Cost list is defined in Reference SP General Mapping be established
Security sub type Code for each sub-
type)
Large Trade Size Definition of principal amount according to product sub $500,000
type according to the list This list is defined in (Defaults may
Reference SP General Mapping Security sub be established
type Code for each sub-
type)
Total Cost –
Default
Product Sub-Type Exclude List All the Product sub types that should be excluded
from the analysis
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Detection Models
Examples
For sample security list XYZ:
CUSIP Monitoring Start Date Monitoring End Date
511999888 01/01/2014 05/01/2014
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Detection Models
4.3.19.3 Flexibility
Include/Exclude Account Determines which list is used if a specific account • Include (Default)
Priority conflict exists
• Exclude
This definition is per list and drop-down of the list
names from the List of lists
User-Defined Lists
Name Description
List Code The code of the list
The user can define custom lists of transaction types under References SP Trade Review
Custom Transaction Lists.
Name Description
List Code The code of the list
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Detection Models
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Trade Review Alert Detail Screens
Scoring
Business users can adjust the following settings using the options available in the Actimize RCM.
Score Factor Description Default Value
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Trade Review Alert Detail Screens
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Trade Review Alert Detail Screens
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Trade Review Alert Detail Screens
For each scenario, you can view in the expanded area the Current Value (the value being
analyzed), and the Check Value (which can be a threshold, a calculation, or a setting). When
applicable, an issue is generated based on the comparison of values. For some of the scenarios,
a score is assigned based on the Current Value.
The Additional Scoring issue assigns additional scores to alerts based on the number of prior
alerts of account or broker. The score is applied by the ASF rule.
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Trade Review Alert Detail Screens
The link opens a window that provides additional information about the account portfolio
associated with the trade under evaluation, as shown in the following example.
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Trade Review Alert Detail Screens
The Trades for Fund Family subsection provides mutual fund historical information, refund
calculation and near breakpoint information. The current trade appears in bold. It has the
following calculated fields.
BP Eligible Position Accumulation of trade amount (for each trade), starting from the beginning of
the lookback period and ending with the current trade amount.
Sales Charge % The original sales charge % for each trade, depending on the original sales
charge and trade amount.
Sales Charge After BP The new Breakpoint Schedule Sales Charge Percentage based on the
current trade BP Eligible Position and the current trade product.
New Sales Charge The recommended alternative sales charge based on Sales Charge After
BP.
At the bottom of this field’s column (in bold), the final Sales Charge that
should be paid by the account is presented. (This calculation is based on the
New Sales Charge of the current trade minus the Total Refund of all other
trades.)
Refund The recommended refund based on the Original Sales Charge and the New
Sales Charge for each trade.
At the bottom of this field’s column (in bold), the final Refund is presented.
(This is the Total Refund of trades other than the current trade.)
The Breakpoint Schedule subsection provides trade product Breakpoint Schedule percentages.
For information about the Missed Breakpoint model, see Section 4.3.13.5: Missed Breakpoint
(MMB), page 159.
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Trade Review Alert Detail Screens
For information about the ROA model, see Section 4.3.13.7: Rights of Accumulation (ROA), page
162.
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Chapter 5: Trade Blotter
5.1 Overview
The purpose of the Trade Blotter is to enable the review of the trading activity processed
overnight and to evidence the supervisory review in a timely manner. Many aspects of the data
information and presentation format can be customized based on the needs of the organization.
The blotters are created and populated on a daily basis.
NOTES:
• The SP solution supports Trade Blotter as the default blotter type. A custom blotter type may
be created during implementation. For further details see the Actimize FMC Implementer’s
Guide.
• Only one blotter type is supported at a time.
5.2.1.1 As of Trades
Some of the trades in a transaction blotter may be marked As of Trades. These are trades that
may require manual review by the user.
Each blotter displays all trades received by the process engine. There is an expected delay
between the date that the trades are processed by the engine and the trade date, configured
according the organization’s needs. If the period between the Process Date and the Trade Date
is longer than expected, the trade is flagged as a delayed trade (in other words, As of Trade). For
example, your organization may set the expected delay to 3 days; if the trade date is prior to the
three days, then the trade is flagged as a delayed trade (As of Trade).
Different models handle the As of Trades in different ways.
Certain models are not impacted by the trade date since they check trade characteristics that are
not date related. Therefore, these models process all trades, including delayed trades. Models
that include a lookback period in their detection analysis do not process As of Trades since the
delay may impact the detection results. Users must review As of Trade transactions manually for
these models.
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Trade Blotter Methodology
5.2.3 Flexibility
Users can adjust the following settings using the options available in the Actimize RCM.
5.2.3.1 Thresholds
Threshold Name Description Default
Value
Number of days trades Set the number of days before the process date (current date) 0
registration is being that transactions are entered into the blotter
delayed
Account Exclude List Account IDs that the firm may choose to exclude from A33FFS
generating a transaction record DVP, Prop, etc.
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RCM Blotter Display
Branch Exclude List Type Branch ID that the firm may choose to exclude from USANY04
generating a transaction record Inst, Reorg. Etc.
Broker Exclude List Type Broker ID that the firm may choose to exclude from JONES34
generating a transaction record House
Each trade blotter presents transactions that are organized according to the needs of your
organization. Depending on the firm’s supervisory structure, the blotters can be configured to be
more or less granular to accommodate satellite branches, free standing, OSJ, regions, divisions,
etc.
The Blotters module enables users to:
• Review the list of all trade blotters that are relevant for their role
• Add notes to blotters as required
• Electronically sign off blotters to evidence appropriate supervision
• When appropriate, assign blotters to different users
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RCM Blotter Display
The options and features that are available for this tab are described in the following sections.
View/Option Description
All Trade Blotters Shows all trade blotters that the logged-on user has permission to view
Signed Trade Shows only trade blotters that have been signed
Blotters
Signed and Shows only those trade blotters that have been signed and materialized;
Materialized (materialization is when the report becomes a static file managed by the RCM).
Trade Blotters
[Reset View] Clears any filters that may be in effect, restores this current trade blotter view’s
default sorting order, and updates the data.
[Set as Default Enables you to select any view that is available in the drop-down list and set it as
View] your personal default view; this is the view that is automatically displayed each
time you access the Trade Blotter List after login.
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RCM Blotter Display
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RCM Blotter Display
Column Description
Name/Icon
This is the state indicator column. It may display icons that provide information about
the requirements or state of the blotter sign-off status, as follows:
indicates that the blotter must be reviewed and signed off
indicates that the blotter was signed off
Alerted Displays the number of trades in the selected blotter that have Alerts.
Trades
Indicates that the corresponding blotter is assigned to me. When no icon appears, the
blotter is assigned to a different user or is unassigned.
Blotter ID The ID string of the selected trade blotter. This string is used internally by the system
and can be used when referring to a trade blotter. It appears in the list as a link,
enabling you to click it and view the trades for the corresponding trade blotter.
Blotter Date Indicates the date when the trade blotter was generated.
Blotter Type Each blotter type contains a unique ‘Trade View’ with its unique list of fields and
properties. The list of blotter types is defined according to the needs of your
organization.
No. of Displays the number of trades that have been reviewed for the specific trade blotter.
Trades
Reviewed Displays the percentage of trades that have been reviewed in the specific trade blotter.
Trades
Owner Name of the user responsible for the selected trade blotter.
Business Indicates the full name of the current BU, as it displays in the trade blotter.
Unit
Signoff Date When appropriate, the date that the trade blotter was signed off.
Signoff User The user that signed off the trade blotter.
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Trade Blotter Tasks
NOTE:
For additional detailed information about how to use these tasks, refer to the Actimize Risk Case
Manager (RCM) Reference Guide.
Click to search through the blotter using the fields and define a filter criteria for a search not
defined in the drop-down list box.
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Trade Blotter Tasks
When there is at least one open alert associated with the selected transaction, clicking Review
opens the Review section that enables you to:
• Change the status of the selected transactions to Reviewed
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Trade Blotter Tasks
• Add a note to the selected transactions(s); you can choose to add a note to any transaction.
• Change the status of all associated open alerts
• Add a note to alerts when you change their status
Multiple users can review transactions in the same trade blotter.
Item Date
Click to select the date that you want to appear as the Item Date.
Step By default, all new items are automatically assigned the status Ready. After
generating the alert, use the Change Status action link to change it, if required.
Business Unit Assign a Business Unit to the selected item. Only users with permission to view
alerts assigned to this Business Unit will see this alert in their Alerts List.
Click beside the Business Unit field to open the Business Unit Explorer,
which enables you to select the Business Unit that you require for the alert.
The wizard also enables you to add a note to the alert.
When the item is saved, it is added to the Alerts List.
5.4.4 Sign-Off
Selecting one trade blotter (selecting the checkbox beside the required trade blotter) and clicking
the Sign-Off action link in the actions bar opens the Sign-Off Blotter window.
It includes the following information and options:
• Total trades – total number of trades for this transaction blotter
• Reviewed Trades – number of transactions that have been reviewed
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Trade Blotter Tasks
• Alert on trades – number of alerts that are attached to transactions in this trade blotter
• Add Note – enables you to add a predefined or free text note that is attached to the trade
blotter
Once a blotter has been signed off, you may go back to search it. Trade blotters must be signed
off by a single user.
Element Description
Related The action that the user was performing when the note was added.
Action Notes can be added to a trade blotter while performing any of the following actions. You
can add notes from the general trade blotter list by selecting any blotter and then
performing one of the following:
• Add Note – add a note directly from the trade blotter list or when viewing the history
of notes
• Sign off – add a note when signing off a selected trade blotter
• Assign to User – add a relevant note about this action from the Assign to User
window
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Trade Blotter Tasks
Element Description
You can add a note to a specific transaction in the trade blotter when you select a
specific transaction in the Blotter Detail window and change the status of the transaction
to Review/Unreview.
You can also add notes from the Blotter Details window for any trade blotter by selecting
Add Note or Sign off at the top of the details window.
Column Description
Date Shows the date when the action occurred.
Action Shows all actions that were performed on the selected trade blotter; for example, if you
use the Sign off action, this information appears here.
History Line Shows more detailed information about the action. For example, if someone assigns
the selected trade blotter to a different user, the details (previous user and new user
names) appear here.
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Trade Blotter Tasks
5.4.8 Assign
Selecting a blotter and clicking the Assign action link in the actions bar opens the Change
Blotter User/BU window, where you can assign the selected blotter to:
• A different Business Unit
• A different user than the one who is currently the owner of the blotter
When you assign a new user, make sure that this user has permissions to deal with the trade
blotter you’re assigning.
Changes made in this window are stored and can be viewed in the View History window.
The Change Blotter User/BU window has the following information and options.
Assign to me Allows you to assign the selected blotter to yourself, indicating that you are the user
who is responsible for dealing with it.
5.4.9 Un-Review
Selecting one reviewed transaction or more (by selecting the checkbox next to the reviewed
transactions) and clicking the Un-Review action link in the actions bar opens the Un-Review
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Export/Print
window, where you can add a note to change the status of the selected transactions to
Un-Reviewed.
This window has the following option:
• Add Note – add a predefined or free text note that is attached to the transaction(s)
5.5 Export/Print
The Export/Print links enables you to print transactions and export information about them to
external files.
5.5.1 Export
The Export links export trade blotter information as a comma delimited file (CSV) that can be
opened by popular spreadsheet programs like as Microsoft® Excel.
Select a blotter in the Trade Blotter List and click the Export link to open a standard Windows
download dialog that enables you to save the selected blotter to a CSV file format.
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Hosted Platforms
Growth 12 Growth 10
Tenant
Growth 10
Ranges: The user values (tenant or host) override all the default values associated
with that score or threshold. For example, if the tenant defines any user values, the
default values are not in used in the logic.
Example:
In the following scenario, the host defines a specific score that contains default
values. The tenant defines the same score with default values and user values. In this
case, the tenant user values for the scoring scale and values (highlighted in yellow)
will override the host values.
Host
10 12
20 15
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Hosted Platforms
Tenant
10 12 10 30
20 15 15 40
▪ Reference/mapping: This kind of definition does not override all the values. The code
uses a merge of the default values and user values. Note that if the user defines a value
that contains a code that exists in the default values, it overrides the default value. For
example:
Tenant – the user values logic uses a merge of:
The tenant user values overriding the default values with the same code
All the other user values
All the other default values
Example:
In the following scenario, the host defines a specific list that contains default and user
values. The tenant defines the same list with a default value and a new user value. In
this case, the application merges the host user value with the tenant default value
and adds the new tenant user value (highlighted in yellow below).
Host
2 Moderate 2 Moderate_Host_Custom
Host
2 Moderate 2 Moderate_Host_Custom
Tenant
2 Moderate_Host_Custom 3 Moderate_Tenant_Custom
Tenant
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Hosted Platforms
Tenant
2 Moderate_Host_Custom 3 Moderate_Tenant_Custom
2 Moderate_Host_Custom
Host
ABC 1/1
Tenant
Tenant
Default User
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Hosted Platforms
Tenant
If the tenant selects a definition that is a domain value type, it works according to the
reference/mapping definition.
Example:
In the following scenario, the new tenant user values (Stated Risk Tolerance Risk
Category, which are domain values) override any default values and it works as it is in
the mapping dropdown.
Host
Tenant
If the new risk factor is a new type defined as a custom risk factor (such as Dynamic
Custom Risk Factor), the values used should be the ones defined in the reference. It
should work the same as any factor (this can be range or domain value).
If for the client the values are domain values and are defined on the same factor, it
works according to the threshold/scoring definition for domain values and overrides
existing values.
If for the client the values are range values and are defined on the same factor, it
works according to the threshold/scoring definition for ranges and overrides all the
values when there is one user value.
• Tenants can only see the segmented data for which they are assigned permissions.
• Hosted platforms must be configured.
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Chapter 6: Account Search
6.1 Overview
As part of compliance tasks, users may need to view account details even when an alert is not
generated on an account. Also, they can use this feature to view more detailed account
information if an alert type provides only partial account information in the Alert Details window.
The Account Search subtab in the Research module of the RCM requires users to enter a
unique account identifier (for example, branch code or account number) to view, on demand, the
latest account details.
The results of the Account Details search include all the default alert details tabs except for
Focus Issues.
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Chapter 7: Risk-Related Calculations
This chapter describes the logic used by the SPO, SPC and UTR models for calculating the risk
of a security.
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Detailed Calculations for Security Risk
The risk for low priced securities is calculated according to the following calculation
A security is defined as low priced if:
[Security Price] ≤ Low Price Equity Security Threshold
Risk calculation:
If the security has Beta defined:
Security Risk Value =
Max (Low Priced Equity Security Risk Value Threshold, Security Risk Value calculated from Beta)
If the security does not have Beta defined:
Security Risk Value
= Max (Low Priced Equity Security Risk Value Threshold, Security subtype risk Threshold)
If a security is considered low priced, then it cannot be used to reduce the risk of the portfolio.
Therefore, the risk sign will be positive for the portfolio risk calculations.
Example 2
If in example 1 CUSIP 1111AAAAA has a market value of $100,000 from a quantity of 25,000
shares priced at $4,
Then:
Security Price of $4 is less than the Low Priced Equity Threshold of $5.00, and so
Security Risk Value for 1111AAAAA = Max (3.51, 2.4) = 3.51
Security Risk Sign = +1
If the security does not have a Beta and does not qualify as Low Priced equity, return NULL.
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Detailed Calculations for Security Risk
Where:
• Weight of Rating is according to the Weights for Fixed Income Rating threshold
• Risk Value of Rating is according to the Risk Rating tables available from the RCM in
Settings SP General Rating.
A weight of 0 means that the agency’s ratings are not used in the risk calculation.
If the agency does not have a rating for the security, then the weight for that agency for that
security is 0.
If the security does not have any rating available, return NULL.
Example
Rating (Agency) Weight %
S&P 50
Moody’s 30
Custom 20
S&P and Moody’s ratings are AAA and Aa1 for the security. There is no custom rating.
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Detailed Calculations for Security Risk
The setup of the Risk Value of the rating is 0.5 for S&P rating of AAA, and 0.9 for Moody’s rating
of Aa1.
Security Risk Value = (50 * 0.5 + 30 * 0.9) / 80 = 0.65.
AAA 1 1
AA+ 1 1.4
AA 1 1.5
AA- 1 1.6
A+ 2 1.9
A 2 2
A- 2 2.1
BBB+ 2 2.4
BBB 2 2.5
BBB- 3 2.6
BB+ 3 3.4
BB 3 3.5
BB- 4 3.6
B+ 4 4.9
B 4 5
B- 4 5.1
CCC+ 5 5.9
CCC 5 6
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Detailed Calculations for Security Risk
CCC- 5 6.1
CC+ 5 6.4
CC 5 6.5
CC- 6 6.6
C+ 6 6.9
C 6 7
C- 6 7.1
D 7 7.5
Aaa 1 1
Aa1 1 1.4
Aa2 1 1.5
Aa3 1 1.6
A1 2 1.9
A2 2 2
A3 2 2.1
Baa1 2 2.4
Baa2 3 2.5
Baa3 3 2.6
Ba1 4 3.4
Ba2 4 3.5
Ba3 5 3.6
B1 5 4
B2 5 4.5
B3 5 5
Caa1 6 5.9
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Detailed Calculations for Security Risk
Caa2 6 6
Caa3 6 6.1
Ca 7 6.5
C 7 7
P1 1
P2 1.5
P3 2
MIG1 1
VMIG1 1
MIG2 1.5
VMIG2 1.5
MIG3 2
VMIG3 2
SG 3.5
Below average 2.8 2.55 2.3 2.05 1.8 1.55 1.3 1.05 0.8 0.55
Average 2.85 2.6 2.35 2.1 1.85 1.6 1.35 1.1 0.85 0.6
Above Average 2.9 2.65 2.4 2.15 1.9 1.65 1.4 1.15 0.9 0.65
High 2.95 2.7 2.45 2.2 1.95 1.7 1.45 1.2 0.95 0.7
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Detailed Calculations for Security Risk
Based on the following example, a mutual fund in a category rated 3 with a Morningstar Risk
Rating below average will have a risk value of 2.3.
If there is no Morningstar Category for the security, the solution returns NULL.
Category Rating 1 2 3 4 5 6 7 8 9 10
(Columns) / Morningstar
Risk Rating (Rows)
Low 5.5 5 4.5 4 3.5 3 2.5 2 1.5 1
Below average 5.6 5.1 4.6 4.1 3.6 3.1 2.6 2.1 1.6 1.1
Average 5.7 5.2 4.7 4.2 3.7 3.2 2.7 2.2 1.7 1.2
Above Average 5.8 5.3 4.8 4.3 3.8 3.3 2.8 2.3 1.8 1.3
High 5.9 5.4 4.9 4.4 3.9 3.4 2.9 2.4 1.9 1.4
Based on the following table, an ETF in a category rated 3 with a Morningstar Risk Rating below
average will have a risk value of 4.6.
If the Morningstar Risk Rating is not available, the solution defaults to Average and the
corresponding risk value in the risk table is used.
If there is no Morningstar category available for the security, the solution returns NULL.
Below average 2.8 2.55 2.3 2.05 1.8 1.55 1.3 1.05 0.8 0.55
Average 2.85 2.6 2.35 2.1 1.85 1.6 1.35 1.1 0.85 0.6
Above Average 2.9 2.65 2.4 2.15 1.9 1.65 1.4 1.15 0.9 0.65
High 2.95 2.7 2.45 2.2 1.95 1.7 1.45 1.2 0.95 0.7
If the Morningstar Risk Rating is not available, the solution defaults to Average and the
corresponding risk value in the risk table is used.
If there is no Morningstar category available for the security, the solution returns NULL.
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Detailed Calculations for Security Risk
Options that are less than or equal to 30 days from expiration are considered short-term options.
Options with more than 30 days but less than or equal to 270 days from expiration are
considered regular term options. Above 270 days they are considered long-term options.
Accordingly, if the option’s position is long, based on the above definitions of the option, the Risk
Value will be used, which is configured in the Long Option Risk Value threshold.
If the option’s position is short, then based on the above definitions of the option, the Risk Value
will be used, which is configured in the Short Option Risk Value threshold.
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Detailed Calculations for Security Risk
Security Subtype Defines the default risk for each product User defined
Default Risk subtype
Threshold group: Product Risk
Mutual Fund Risk Defines the risk of mutual funds based on the See Risk Method 3
Value category and Morningstar ratings
Threshold group: Product Risk
ETF1 Risk Value Defines the risk of ETFs based on the See Risk Method 4 - Exchange
category and Morningstar ratings Traded Funds/Notes (ETF1)
Threshold group: Product Risk
ETF2 Risk Value Defines the risk of ETFs based on the See Risk Method 5 –
category and Morningstar ratings Exchange Traded Funds/Notes
Threshold group: Product Risk (ETF2)
Short Term Option Defines whether an option is short term 30 days (default)
based on the expiration date.
Threshold group: Product Risk
Long Term Option Defines whether an option is long term based 270 days (default)
on the expiration date.
Threshold group: Product Risk
Long Option Risk Defines the risk values of long term options Option Risk Value
Value Threshold group: Product Risk Characteristic
NOTE: Short term In 1.5
The configuration of these values has the Money
changed in the recent version. You have to
configure the values again in your solution. Short term Out 3
of the Money
Regular term In 2
the Money
Long term In 3
the Money
Short Option Risk Defines the risk values of short term options Option Risk Value
Value Threshold group: Product Risk Characteristics
Regular term In 4
the Money Call
Regular term 3
Out of the
Money Call
Short term In 5
the Money Call
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Detailed Calculations for Security Risk
Regular term In 5
the Money Put
Regular term 3
Out of the
money Put
Short term In 6
the Money Put
Weights for Fixed Defines the weight of each rating factor that 0%-100%
Income Rating is included determines the risk of fixed
income securities.
Threshold group: Rating
Enable Country Risk Defines whether to include the country risk in User defined (at the product
Correction the total risk calculation for a security. subtype level)
Threshold group: Product Risk
Time to Maturity Risk Defines an additional risk that can be added User defined (months)
Correction to a security according to the time of maturity
of the security. Used for fixed income
securities.
Threshold group: Product Risk
Enable Margin Risk Defines whether to include in the calculation • Yes (default)
Multiplier of the portfolio risk, an additional risk based
on the margin risk. • No
Threshold group: Portfolio Risk
Margin Multiplier Defines the risk that should be multiplied by Margin Ratio Margin
the portfolio risk according to margin ratio. Risk
Location: Multiplier
Settings Thresholds SP Account 0-10% 1.05
Review/SP Daily Account Review SPO
10-20% 1.10
20-30% 1.15
30-40% 1.2
40-50% 1.25
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Portfolio Risk
Risk Method Defines the name of each of the risk methods used to 1-6
determine the risk of a security. Each risk method is
based on the product subtype.
Rating Defines the name of the rating indexes used to define the • InHouse
risk of fixed income securities.
• MF Rating
NOTE:
• Back Rating 3
Users can add custom ratings. Moodys
• Back Rating 4
S and P
Default Countries Lists the countries that are referred to as base List of country codes
countries. The rest of the countries are considered
foreign.
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Detailed Calculations for Account Calculated Tolerance to Risk
7.3.1 Calculation
1. Identify Risk Volatility Value for each of the factors based on the Risk Category Tables.
For example, Customer John Doe’s profile and the associated risk values are:
Factor Value Risk Volatility
Value
Investment Objectives Income (60%) – Primary Growth (40%) 1.6
– Investment Objective #2
Customer’s Age 73 2
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Detailed Calculations for Account Calculated Tolerance to Risk
NOTE:
The higher the risk value, the more aggressive the risk profile.
Investment Objective risk is calculated as the weighted average of the account’s Investment
Objectives. The account can have up to four Investment Objectives - one Primary and three
additional objectives. The weighted average is calculated based on the weights in the
Investment Objective Weights threshold.
2. Calculate the account tolerance to risk using the weighted average based on the Risk Factors
Weights (User Values) and Risk Volatility Values. For example: Risk Factor Weights are
7.3.1.1 Flexibility
Business users can adjust the following settings using the options available in the Actimize RCM.
References (SP General References)
NOTE:
The Reference settings in the following table should only be configured by an implementer.
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Detailed Calculations for Account Calculated Tolerance to Risk
Custom Risk Factor If the Risk Factor is Range, you should define the list of None
Values values for the Constant type custom risk factors. For
example, if Custom Risk is defined as Occupation, a list of
occupations is required in this setting.
Account Risk Score After defining the risk factor, you must define the score scale None
Thresholds that will determine risk factor. If the risk factor type is Range,
define a range of numbers with their score values; if the risk
factor type is Domain Value, define a score for each value
that was defined above.
Thresholds
Threshold Name Description Default Value
Maximum Age Age over which account risk tolerance is 70
determined according threshold “Account
Risk Tolerance”
NOTE:
If zero is assigned to this threshold then
the system does not use the Account
Highest Risk by Age threshold for the
Account Tolerance Risk calculation.
Account Highest Risk by The default Account Risk Tolerance Risk Value 1
Age when the account age is over the
Maximum Age Threshold (see above
threshold)
Risk Factor Weights Assign weights for risk factors, including • 16.66% for each of the
custom risk factors pre-defined risk factors
(Investment Objective,
Stated Risk Tolerance,
Age, Annual Income,
Liquid Net Worth, Total
Net Worth)
• Tax Status – 0%
• Investment Experience –
0%
• Investment Time Horizon –
0%
• Liquidity Needs - 0%
Investment Objective Assign weights to each of the four pre- 100% to the Primary
Weights defined investment objectives. Investment Objective
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Detailed Calculations for Account Calculated Tolerance to Risk
Age Codes Assign risk values for each age group. See below.
Annual Income Assign risk values for each income See below.
bracket.
Liquid Net Worth Assign risk values for each range of liquid See below.
net worth.
Total Net Worth Assign risk values for each range of total See below.
net worth.
Dynamic Custom Risk Assign risk values for each custom risk User-defined risk factors
Factor factor.
Income 1
Growth 2.5
Income/Growth 2
Speculation/Profits 3
Undecided 1
N/A 1
Calculation: None
Format: Number
Path: Settings > Threshold > GLB SP > Account Risk
NOTE:
The Investment Objective risk is calculated as a weighted average of the account Primary
Investment objective and Additional Investment Objectives 2-4. The risk in the above table is
assigned to each objective, and a weighted average is calculated based on the weights in the
Investment Objective Weights threshold.
Name Description Value
Stated Risk Default values for Stated Risk Stated Risk Tolerance Risk Value
Tolerance Risk Tolerance Risk Category
Category Conservative 1
Moderate 2
Aggressive 3
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Detailed Calculations for Account Calculated Tolerance to Risk
Age Risk Category Default values for Age Risk Category Age Codes Risk Value
0-20 1
21-50 3
51-59 2.5
60-75 2
>76 1
Calculation: None
Format: No Format
Path: Settings > Threshold > GLB SP > Account Risk
Annual Income Default values for Annual Income Risk Annual Income Risk Value
Risk Category Category
0-25,000 0.5
25,001-50,000 1
50,001-100,000 2
100,001-150,000 2.5
150,001-250,000 2.5
250,001-500,000 2.5
500,001-999,999 3
>1,000,000 3.5
Calculation: None
Format: No Format
Path: Settings > Thresholds > GLB SP > Account Risk
Liquid Net Worth Default values for Liquid Net Worth Risk Liquid Net Worth Risk Value
Risk Category Category
0-30,000 1
30,001-50,000 1
50,001-100,000 2
100,001-500,000 2
500,001-1,000,000 2.5
1,000,001-4,999,999 3
>5,000,000 3.5
Calculation: None
Format: No Format
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Detailed Calculations for Account Calculated Tolerance to Risk
Total Net Worth Default values for Total Net Worth Risk Total Net Worth Risk Value
Risk Category Category
0-100,000 0.5
100,001-500,000 1
500,001-1,000,000 2
1,000,001-2,000,000 2
2,000,001-5,000,000 2.5
5,000,001-10,000,000 3
>10,000,000 3.5
Calculation: None
Format: No Format
Path: Settings > Thresholds > GLB SP > Account Risk
Tax Status Risk Default risk values for Tax Status Tax Status Risk Value
Category
10%> 0.5
10%-30% 0.75
30%-60% 1
60%-80% 1.5
80%< 2
Calculation: None
Format: Number
Path: Settings > Thresholds > GLB SP > Account Risk
Investment Default risk values for Investment Investment Experience Risk Value
Experience Risk Experience
Category 1> 0.5
1-3 1
3-6 2
6 3
Calculation: None
Format: No format
Path: Settings > Threshold > GLB SP > Account Risk
Investment Time Default risk values for Investment Time Investment Time Risk Value
Horizon Risk Horizon Horizon
Category
1> 0.5
1-3 1
3-6 2
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High-Risk Position Calculations
Calculation: None
Format: No Format
Path: Settings > Threshold > GLB SP > Account Risk
Liquidity Needs Default risk values for Liquidity needs Liquidity needs Risk Value
Risk Category
6> 3
6-9 2
9-12 1.5
12-18 1
18< 0.5
Calculation: None
Format: No Format
Path: Settings > Thresholds > GLB SP > Account Risk
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High-Risk Position Calculations
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High-Risk Position Calculations
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Account Tolerance to Risk Calculation
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Chapter 8: Scoring Algorithms
The main purpose of alert scoring is to prioritize alerts based on their severity. The system uses
several methods to assign a score to alerts generated by the detection models, thus enabling risk-
driven analysis and handling.
Scores are calculated according to a formula that summarizes the relevant scoring factors.
Authorized users may control the way scores are calculated by modifying thresholds, weights and
other parameters.
The alert score is calculated based on various factors.
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Scoring Calculations
• An exact score value assignment where no scoring scale is used for score assignment. For
example, in the case of investment objectives, each objective is assigned a different score,
as shown in the example below:
• An exact score value assignment that is based on a scoring scale. In the example below, a
threshold is set for the cost equity ratio and the score is assigned based on the degree to
which the detection result varies from the threshold:
When a score is calculated based on a scoring scale, the solution determines the appropriate
score scale that is used as follows: a detection result falls within a range when it is greater
than or equal to the low limit and less than (but not equal to) the next low limit. In the example
shown above, a detection result of 9.9 will receive the score point of 40, the result of 10 will
receive the score point of 50 and the result of 210 will be assigned a score of 80.
• A proportional score value assignment that is based on a scoring scale. In the example
below, if the ‘Fees charged to Commissions Waived’ ratio falls between 25 and 50 and a
proportional score value is used, then the score value is assigned based on the degree to
which the ratio varies from the limit.
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Chapter 9: Policy Manager
The Policy Manager provides an option to add custom rules to existing rules in the ACR, DAR
and TRR model groups.
Settings
AIS
Client Data
Model Rules
Alert Display
Data Integration
Policy Manager
Rules
App Data
9.1 Defaults
The default behavior is the current rules that are defined in the SP solution. It is possible to add
more rules using the Policy Manager, under the assumption that the out of the box rules do not
depend on the new Policy Manager rules.
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Custom Lists
Fields:
List ID String
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Policy Manager Context
After selecting the user values of certain list you can add members to the list.
Location: Settings Lists <Model Name> Custom List <List Name>
Title: Custom List Members
Fields:
Region String
Value String
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Configuring the Focus Issues Description
Upper Table:
1. Issue type:
▪ The string of the identifier of the rule that was configured by the user
▪ Default value the code of the rule that was defined in the policy manager.
2. Description:
▪ The string of the rule name that was configured by the user
▪ Default value the name of the rule that was defined in the policy manager.
3. Score: The score that was defined in the policy rule, default value: 0
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Actions
Lower Table:
The lower table can contain several rows that will be configured by the implementer/client IT. The
lower table will not be displayed if it was not configured. The lower table will contain the following
attributes:
• Scenario
• Scenario Description
• Current Value
• Check Value
This configuration can be performed using an exit point:
Input: Policy manager Context (UDT)
Rule identifier (char)
Output:
Issue (tuple)
Issue Type (char)
Description (char)
9.7 Actions
The actions that can be performed from the Policy Manager include:
• Score: The drop down contains the values: 10, 20, 30, 40, 50, 60, 70, 80, 90, 100
• Create Separate Alert: Allow creating a separate alert from one or multiple of the custom
issues. The drop down contains the values Yes, No
• Line of Business: Adding the new rule to a certain line of business. The drop down contains
list of the Trade Review lines of business and ‘all’. The action is relevant just if the ‘Generate
Alerts Using Line of Business’ is on. The Policy Manger rule is added to all alerts of the
selected line of business (or all lines of business).
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Actions
No Yes No No 2 No
No Yes Yes No 2 No
No Yes No Yes 2 No
No No Yes No 1
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Functions
9.8 Functions
Functions are complex fields in the context of the expression browser.
9.9 Operators
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Operators
• Output – Boolean(True\False)
9.9.5 Daily Positions of the Products – Asset Allocation – For Daily Account
Review Only
This is the ability to compute the daily positions of the products in a specific asset class as a % of
the portfolio market value from a purely asset mix perspective. For example, the sum of the
market value of all products classified as equities in the account portfolio should be available.
The same calculations should be available for Fixed Income, Cash, Options and other asset
classes.
• Input:
▪ String (the asset class code)
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Operators
EQ Equity
FI Fixed Income
FND Fund
FX Forex
OTH Other
▪ Double
• Operator:
▪ Is equal to
▪ Is not equal to
▪ Is less than or equal to
▪ Is less than
▪ Is greater than or equal to
▪ Is greater than
9.9.6 Daily Positions of the Products – Risk – For Daily Account Review Only
This is the ability to compute the daily positions of the products in a specific asset class as a % of
the portfolio market value from a risk classification perspective. For example, the sum of the
market value of all products classified with risk as High, Medium and Low in the account portfolio
should be available.
• RISK_LEVEL table use:
▪ Targets for accounts in order to check if the real positions match to the targets of asset
class or product risks.
▪ Risks for products in order to check if the concentration of a product in the positions.
For example:
RISK_TYPE_CD ENTITY_TYPE_CD RISK_TYPE_DESC
SP_LOW PRODUCT PRODUCT LOW RISK
SP_MEDIUM PRODUCT PRODUCT MED RISK
• Input:
▪ String (the risk classification code)
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Backward Compatibility
H High
▪ Double
• Operator – Drill-down Piker with the following values:
▪ Is equal to
▪ Is not equal to
▪ Is less than or equal to
▪ Is less than
▪ Is greater than or equal to
▪ Is greater than
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Chapter 10: Setting Up Policy Manager Rules
NOTE:
The Policy Manager supports the Account Review (ACR), Daily Account Review (DAR) and
Trade Review (TRR) model groups only.
10.1 Overview
Sales Practices custom rules generation is an add-on to the SP solution allowing specially
designated client users and Actimize Professional Services (PS) personnel to create new custom
rules based on the data available, and include the issues generated within the different SP alert
levels.
Settings
AIS
Client Data
Model Rules
Alert Display
Data Integration
Policy Manager
Rules
App Data
Each client has its own unique requirements and policies to monitor customer accounts and
trades. As a result, you often need to create custom rules that generate appropriate alerts for the
Compliance team to investigate. These custom rules often use much of the same data and
calculations already leveraged in the SP system but currently PS and/or the client do not have
full access to this data. This functionality enables easy and effective custom rules creation,
utilizing SP data and allowing the issues raised to be consolidated with out-of-the-box SP alerts.
The Policy Manager allows you to define and adjust RCM Rules that affect the Solution’s
decisions. For example, the user may adjust a Rule in order to enable transactions for VIP
customers or delay transactions from suspicious IP address ranges.
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Setting up Policy Rules
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Setting up Policy Rules
2. For each new rule enter the name and identifier for the rule within the General tab within the
lower section of the screen
For each new condition, a selection box enables you to select either Field or Expression.
The following options let you define a condition.
Option Description
Select one of the following options:
• Field – the default selection that enables you to select a field from the
drop down menu.
• Expression – click the picker to open the expression builder
window, which enables you to enter expressions for the condition.
The default display for the condition includes a drop-down list box for
selecting a field for the condition.
Discards the changes that have been made to the condition in editing mode
and displays the link.
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Setting up Policy Rules
The options in the filtering menu change according to the type of data that is in the selected
field (for example, a field that has date related data has different filtering options than a field
that stores data on amounts).
Once a rule has been defined, the following options appear:
Option Description
Prepend Condition Adds the new condition before all the other conditions
Append Condition Adds the new condition after all the other conditions
2. If you select an Expression, an icon appears allowing you to open the expression builder in
order to build a complex custom expression, based on the context available for the rule type.
For more information about using the expression builder within the Policy Manager, refer to
your Risk Case Manager Reference Guide, under the Draft Policy Tab Expression Builder
section.
3. If you select a field, a new selection box appears with a drop-down list of available fields.
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Setting up Policy Rules
The following actions can be executed using the buttons at the bottom right of the page.
The toolbar of the Expression Builder includes the following options.
• Clear – clears the current contents of the expression
• Validate – validates that the expression is valid and does not include errors. To validate an
expression, click Validate. If the expression is valid, then an “Expression is valid” message
appears with a timestamp. If the expression is not valid, an “Expression is invalid” message
appears with a timestamp. A list of errors also appears as shown in the following example.
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Setting up Policy Rules
4. Click OK.
Results starting with the search term appear before results that only contain the search term and
are grouped in the following order:
1. Constants.
2. Platform lists.
3. Fields.
4. Functions.
All grouped results are ordered alphabetically.
Select the relevant result and press the Enter or Tab for the result to be displayed in the
expression builder. The keyboard shortcuts for undo (Ctrl + Z) and redo (Ctrl + Y) are supported.
When the AIS server is down, an indication appears.
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Setting up Policy Rules
NOTE:
It is recommended to use this feature when the AIS server is up and running.
When the AIS server is down there are partial autocomplete results that include functions, fields
and any previous cached results that are kept as long as the expression builder window remains
open.
Is not equal to Opens an additional field that enables you to enter a value that is not equal to
the compared field.
In List Opens an additional field that enables you to enter a comma delimited list of
values that are equal to the compared field.
Separate the entered strings with commas (for example, John,Nancy,Ken).
Starts with Opens an additional field that enables you to enter the initial character(s) of the
entities that are to be included.
Ends with Opens an additional field that enables you to enter the final character(s) of the
entities that are to be included.
Not In List Opens an additional field that enables you to enter a comma delimited list of
values that are not equal to the compared field.
Separate the entered strings with commas (for example, John,Nancy,Ken)
Contains Opens an additional field that enables you to enter character(s) in the entities
that are to be included.
Exists in List Opens an additional field that enables you to select a relevant Platform List.
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Setting up Policy Rules
Option Description
Is in Account (monthly Includes strings contained in the Account/Trade Review list
and daily)/Trade
Review List
Option Description
Is equal to Opens an additional field that enables you to enter a value that is equal to the
compared field.
Is not equal to Opens an additional field that enables you to enter a value that is not equal to
the compared field.
Is Less than or Opens an additional field that enables you to enter a value. The criterion is for all
equal to values that are less than or equal to the value that was entered.
Is Less than Opens an additional field that enables you to enter a value. The criterion is for all
values that are less than the value that was entered.
Is greater than or Opens an additional field that enables you to enter a value. The criterion is for all
equal to values that are greater than or equal to the value that was entered.
Is greater than Opens an additional field that enables you to enter a value. The criterion is for all
values that are greater than the value that was entered.
Is Opens an additional field that enables you to enter a value. The criterion is for all
values that are equal to the value that was entered.
Between Opens two additional fields that enable you to enter values. The criterion is for all
the values that are between the numbers that were entered.
Is not between Opens an additional field that enables you to enter a value. The criterion is for all
values that are not equal to the value that was entered.
Exists in List Platforms lists enable the user to create rules based on lists by using this
operator and selecting the relevant platform list
Proportion to Calculates the Account Tolerance to Risk and return true or false according to
Account Risk (for the operator input selected
TRR only)
Proportion to Calculates the Portfolio Risk and return true or false according to ‘operator‘ input
Product Risk (for chosen
TRR only)
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10.2.5.3 Boolean
The filtering menu provides the following options for fields that include Booleans that can be
calculated as True or False. Some of these options include:
Option Description
Is equal to Opens an additional field that enables you to enter a value that is equal to the
compared field.
Is not equal to Opens an additional field that enables you to enter a value that is not equal to
the compared field.
Option Description
On specific date Opens an additional field that enables you to enter a date. The criterion is for all
records that occurred during the specified date.
After specific date Opens an additional field that enables you to enter a date. The criterion is for all
records that occurred after the specified date.
After or equal to Opens an additional field that enables you to enter a date. The criterion is for all
specific date records that occurred after or on the specified date
Before specific date Opens an additional field that enables you to enter a date. The criterion is for all
records that occurred before the specified date.
Before or equal to Opens an additional field that enables you to enter a date. The criterion is for all
specific date records that occurred before or on the specified date.
Between dates Opens two additional fields that enable you to enter dates. The criterion is for all
records that occurred between the specified dates.
Is Not Between dates Includes all values that are not between specified dates
After specific time Includes all values that are after the specified time.
After or Equal to Includes all values that are after or at the same time as the specified time.
specific time
Before specific time Includes all values that are before the specified time.
Before or Equal Includes all values that are before or at the same time as the specified time.
specific time
Between time Includes all values that are between specified times.
Is Not Between time Includes all values that are not between specified times
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Option Description
Exists in List Opens an additional field that enables you to select a relevant Platform List.
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6. If you want to use the fields in the dropdown field of the Policy Manager, define the field in the
RCM Designer.
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Setting up Policy Rules
7. The new field appears in the drop-down list box of the Policy Manager under the group you
defined.
8. To add a field to the SP_TRR_TradeReviewPolicy custom policy, define a custom field under
Trade Review 561 – Customization SP_TRR_TradeReviewPolicy rule.
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Setting up Policy Rules
9. In the RCM Designer, select the Trade Review policy and refresh the field tab.
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Setting up Policy Rules
NOTE:
Custom fields of type set only appear in the expression.
10.2.7 Operators
Once you have selected a field, a drop-down menu appears allowing you to select an operator.
Descriptions of all built-in filtering operators are available in your Risk Case Manager Reference
Guide.
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Setting up Policy Rules
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Setting up Policy Rules
10.2.8.1 Score
Define the score of the created rule (it can be between 10 and 100.
If you do not define a score, the score of the rule is 0.
To activate rules:
1. Select (click the checkboxes for) each of the rules that you want to activate for the current
policy.
2. Click the More Actions drop-down menu and then click Activate.
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Appendix A: Policy Manager Context
The following is the list of custom fields that are available for and mapped to the rule-authoring
context when using Policy Manager (for more information about Policy Manager and how to set
up rules, see Chapter 10: Setting Up Policy Manager Rules, page 236).
NOTES:
• The entire set is available in the Expression Builder only.
• These fields apply to the ACR, DAR and TRR model groups only.
Account Data
Group name: Account.
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Fields Common to All Policy Types
Attribute Name FDM Attribute Data Type UDM Table UDM attribute
Acct Maiden Acct_Maiden_Name Char(50) ACCOUNT ACCOUNT_MAIDEN_NA
Name ME
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Fields Common to All Policy Types
Attribute Name FDM Attribute Data Type UDM Table UDM attribute
Business Owner Business_Owner_Na Char(50) PARTY If
Name me party_type.IS_INDIVIDUAL
= 1, FIRST_NAME|| ' '||
LAST_NAME
Else
PARTY_NAME
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Fields Common to All Policy Types
Attribute Name FDM Attribute Data Type UDM Table UDM attribute
Fee Based Term Fee_Based_Term_D Date ACCOUNT FEE_BASED_TERM_DAT
Date ate E
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Fields Common to All Policy Types
Attribute Name FDM Attribute Data Type UDM Table UDM attribute
Is Margin Acct Is_Margin_Acct Boolean ACCOUNT IS_MARGIN_ACCOUNT
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Fields Common to All Policy Types
Attribute Name FDM Attribute Data Type UDM Table UDM attribute
Premium Amount Premium_Amount Double ACCOUNT PREMIUM_AMOUNT
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Fields Common to All Policy Types
Party
Group name: Party
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
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Fields Common to All Policy Types
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Fields Common to All Policy Types
Broker Info
Group name: Representative
Branch Info
Group Name: Branch
The basic information of the current branch.
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
Alerts Data
Process Arguments
Group name: Process Argument
Display Name Type
Date Date
Region String
Segment String
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Fields Common to All Policy Types
Rules detected:
Display Name Type
Description String
Score Double
Scenario String
Score Double
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Fields Common to ACR and DAR Only
Prior Alerts
Group name: Prior Alerts
Display Name Type
Account Calculations
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Fields Common to ACR and DAR Only
Concentration Criteria
Concentration calculations for the current month in ACR and daily in DAR.
Attribute Name Data Type Example
Criteria Account Key Char The account key (for example 123)
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Fields Common to ACR and DAR Only
Criteria Options:
Code Description
Reg Region
Co Country
Is Issuer
Sec Sector
SS Single Security
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Fields Common to ACR and DAR Only
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Fields Common to ACR and DAR Only
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TRR-Specific Fields
TRR-Specific Fields
Exchange
Group name: Exchange.
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
Product Information
Group name: Product
Product
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
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TRR-Specific Fields
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
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TRR-Specific Fields
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
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TRR-Specific Fields
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
Trades Data
Group name: Trade
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TRR-Specific Fields
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
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TRR-Specific Fields
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
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TRR-Specific Fields
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
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DAR-Specific Fields
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
DAR-Specific Fields
Risk Level
Group: Risk Level
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
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DAR-Specific Fields
Attribute Name FDM Attribute Data Type UDM Table UDM Attribute
The following table lists domain values that are relevant to the fields in the above table.
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