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ComplyPlus and Data
At the heart of every computer system is its data. Data comes
from three distinct sources: trading systems and/or accounting systems, trade
record data (FIX, etc.) and reference data such as that from Bloomberg,
Morningstar and Thomson. Integrating your data with ComplyPlus is
relatively straight forward. You do not have to "reformat" your data into
our internal format, instead we can use your data in much the same way as
Microsoft Excel and Access do. The degree to which you can integrate your
trading system depends on your particular system. For instance, some
trading systems are "open" enough to include a compliance check at the time of
order allocation. Call us for more details about how ComplyPlus
integrates with your specific order management/trading system.
Many firms don't have the budget for extensive data feeds to support
compliance. For instance, you might not have a data feed to supply
industry breakdowns for iShares (Index Shares). Without this data,
ComplyPlus can't do the "look through" for this class of asset. However,
ComplyPlus was designed to handle situations where data is missing. For
example, you can build rules that take into account the missing data and
calculate its potential effect by each rule.
Data Overlays
Another problem with data is that it's often incorrect. In some cases,
data may be correct for some purposes, but incorrect for others. A simple
example: You're managing the money for the local chapter of the Brotherhood of
Electrical Workers Union. They want to buy only US securities. As part of
their account setup, you added a client restriction that stops purchasing of
foreign equities. However, you want to buy stock from the disk drive
manufacturer Seagate Technology (STX), based out of California, on behalf of
this client. But Seagate has recently moved its legal domicile to the
Cayman Islands for tax reasons. Is Seagate a U.S. company or a foreign
company? The data you get from your provider says "Cayman". You
call your client and ask how they want to consider Seagate? They give you
the green light to consider purchasing Seagate.
Many such data items are left to interpretation. There is no easy right or
wrong answer; but your data provider has only a single value. And, of course,
there are times when the data is simply wrong. So what do you do with
Seagate? Override the error when you place the trade (this is how most systems
handle these kinds of problems today)? Another way would be to change the
rule to exclude Seagate from testing. This is messy; now you've taken
your "no foreign" rule that was good for any account and made it specific to
the Electrical Workers Union. ComplyPlus provides you another way: data
overlays.
With ComplyPlus' data overlay system, you can change the value from the data
provider and limit the context in which the change is visible. As in the
previous example, ComplyPlus would allow you to create an overlay for the
Seagate domicile data item and apply it to that specific account and that
specific rule. Or in the case of a real data quality problem, you could
apply the change across all clients/portfolios and all rules. After all, when
you get a data quality problem from Bloomberg, who are going to call to fix it?
Any data item in ComplyPlus, including data provided from third parties can be
overlaid allowing different interpretations by client, portfolio or rule. You
can setup the overlay to work for a specific time period. For instance, you can
override a credit rating, but only for the next month. And, you can detect when
the source system changes its value so you can decide what to do in response.
Again, using the Seagate example, what should happen when Seagate's domicile
changes from Cayman to Bermuda, should the overlay still override with USA?
ComplyPlus provides you with the tools to work with the data you have.
Global Table Manager
ComplyPlus ships with a powerful data manager called the Global Table
Manager. It provides in-memory data storage for high-performance data
access. It can load data from wide variety of data sources such as a web
services, xml, Excel, flat-files, databases, and much more. It also
provides services for indexing and data table relations common with most
relational databases today. It provides the unique feature that it can link
data to an individual ComplyPlus object such as portfolios, stocks, bonds,
etc., in much the same way a relational databases links (joins) tables.
All the data in the Global Table Manager can be used as part of rule definition
without having to perform any SQL statements. And it's fast because all the
data is in-memory and fully indexed.
Grouping Manager
ComplyPlus ships with a tool called the Grouping Manager which is used to
create lists and trees for use with rules. Simple lists can be created to
support rules such as exclusion tests. More complex tree structures can
be created to support rules for aggregation. A simple example is a tree
that contains all the countries in the world (bottom of the tree) that rolls up
to various geographic regions (at the top of the tree). By introducing
this tree into a rule, you can build rules that aggregate by geographic region
even though your data only has country information.
Data AddIns
Another way data is provided in ComplyPlus is from a custom AddIn. As an
example, ComplyPlus ships with an AddIn that provides real-time pricing
information. Another example is a ComplyPlus AddIn that provides bond
ratings. ComplyPlus' AddIn capability goes beyond the functionality of
the Global Table Manager by allowing complex functionality as well as
integration of data into ComplyPlus' rule libraries. ComplyPlus ships
with sample source code for several Addins that can be used as templates for
your IT department for creation of your own custom AddIn.
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