False positives are the bane of compliance professionals. Whether it is investment guidelines compliance or electronic communications surveillance, compliance staff has to deal with a large number of false positives before homing in on the real compliance violations. What are the best ways to deal with these situations? How can improved data, process, and automation help? In this CutterCast, we discuss what options are available to the compliance professional in dealing with false positives related to the following:
Gina McCafferty has 30 years of experience in the financial services industry. She served at Cutter from 1999 to 2011 as Principal and Managing Director of CutterResearch, and she was instrumental in growing that business. Gina returned to Cutter in 2017, and established and ran the company’s Wealth Management research division. In 2019, she was appointed to Head of Research, responsible for Asset Management and Wealth Management product development and delivery to over 200 member firms around the globe. Gina was previously at Investit Ltd., where she served for six years as head of the company’s research service. Prior to that, she held senior positions at DST International with product responsibility for their global accounting and performance measurement systems, and at SunGard as Vice President of Client Services for their securities trading products.
Stacia Graham has more than 20 years of experience in investment management, bringing a deep understanding of end-to-end asset management processing and project management to her role as Managing Director at Cutter Research. Prior to Cutter, Stacia worked at Wellington Management Company LLP in Boston in various roles within compliance and operational risk, including leading and managing the global Investment Guideline Compliance team for eight years. She earned a bachelor of science in business administration from Bryant University and an MBA from Bentley University.
Recent research assignments and publications include the following:
Todd Spillane brings more than 20 years of industry experience, with a focus on compliance and legal functions in investment management, to his Senior Director’s role at Cutter Associates. At Cutter, he is the subject matter expert and advisor on compliance initiatives, providing thought leadership as well as strategic and tactical advice. In addition to compliance, his areas of expertise include risk management, valuation, and legal oversight. A featured speaker at various industry forums on compliance-related topics, he has presented on compliance and risk management for investment managers. Prior to Cutter, he held several compliance, general counsel, and COO leadership roles, including most recently as GC, CCO, and COO of AlphaTrAI. He also was Executive Director at Morgan Stanley Investment Management, where he oversaw the compliance program for Morgan Stanley Funds. A graduate of Fairfield University and Western New England School of Law, Todd is a member of the Connecticut Bar.
Shankar Subramanian has over 25 years of industry experience in investment management and technology solutions. Shankar has a deep understanding of investment data management, portfolio management, risk management, investment accounting, and alternative investments. At Cutter Associates, he heads the Risk and Compliance practice, helping client with investment risk management, and asset allocation, as well as providing support for compliance with consulting on trading forensics, communication surveillance, regulatory reporting, and guideline compliance. He advises on, and designs, operating models, selects systems, and implements business and technology solutions. He also leads development of Cutter’s alternative investments practices and the firm’s efforts to provide thought leadership and strategic and tactical advice to asset owner clients.
Prior to joining Cutter, Shankar held senior roles at IBM Global Services and PricewaterhouseCoopers (PwC), advising clients and leading global delivery teams in large engagements. Shankar holds a Bachelor of Science in engineering from the Indian Institute of Technology and an MBA in finance and information systems from the Indian Institute of Management.
Christopher Joe serves as Vice President and Chief Compliance Officer of the SunAmerica Annuity Funds and VALIC Funds and Chief Compliance Officer of the VALIC Registered Investment Adviser. Christopher Joe is responsible for the administration of the Funds’ and Adviser’s Compliance Program. Christopher Joe oversees a team of compliance professionals who monitor each of the Funds for compliance with Prospectus disclosure and federal securities laws. This compliance effort includes providing real-time advice to portfolio managers and traders, forensic and transactional testing, regulatory documentation, project management, policy and procedure review, due diligence requests and participating in new product launches.
Christopher Joe served as the Chief Compliance Officer of PowerShares Capital Management LLC and the PowerShares Exchange-Traded Trusts. As Chief Compliance Officer, Mr. Joe was responsible for ensuring the compliance program was reasonably designed to prevent, detect and correct violations of securities laws. Mr. Joe managed a team of compliance professionals who oversee monitoring of exchange-traded funds across multiple investment strategies – including equity, fixed income, bank loans and multi-asset – for compliance with portfolio-specific and regulatory requirements.
Mr. Joe joined the Invesco Compliance department in 1999 as a compliance manager, taking on roles of increasing responsibility, such as compliance director, until moving to his chief compliance officer roles. Mr. Joe joined Invesco in 1993 as a member of the Fund Accounting department and held multiple positions, including assistant fund accounting manager. Before joining Invesco, he worked as an electronic data processing auditor for Texaco, Inc., specializing in system application audits.
Mr. Joe earned a BBA in accounting from the University of Houston.