SEC Investment Company Reporting Modernization Foundational Work

In a new guide, we discuss the background of the SEC’s Investment Company Reporting Modernization Rules and the potential effects on individual financial institutions.

The snippet below talks about the foundational work companies should have already completed.

By now, you should have a program in place that covers the following work streams:

• Engage Report Filing Provider: Initiate a project with the selected service provider to collect and process data, and file the required forms.
• Determine Data Sources: Flag each required data element and determine internal or external sources, such as custodians and fund administrators. This can be a major undertaking if you are a large entity with multiple custodians, fund administrators, and other third parties.
• Expose Required Data: Conduct development to expose data not currently accessible to clients or available in internal systems, perform aggregation, and custom calculations.
• Map Import Data: You will need to map the incoming data from external sources and your own firm to the reports, and identify any duplicates and incorrect fields.
• Test Filing: Generate files with test data for your service provider to file with the SEC.

If you have a program in place, did you do it correctly?

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Did your program include all stages of planning, analysis, implementation, and QA? Or did you take a tactical approach? If the latter is the case, gaps might exist in one or more of the following areas:

Planning

• Business case and roadmap development
• Identification of project work streams
• Establishment of the program governance model
• Creation of detailed project plans, risk logs, and escalation mechanisms

Analysis

• Documentation of process, data, and technical requirements
• Service provider requirement definition
• Changes to policies and procedures
• Analysis of gaps vs. current state

Implementation

• Definition of the overall solution architecture
• Acquisition of new data sources
• Integration of new and existing data
• Development of data quality checks and approval workflows
• Website upgrades

Quality Assurance

• Development of test plan and test cases
• Test automation
• Integration and user acceptance testing
• Support for mock filings

To learn more about the new rule, you can download the guide here.