Curo: in Latin means "To care for and manage money".  We strive to produce effective compliance solutions that help money managers care for their clients' money.

Privately held, Curo Systems, Inc. was founded in 2001 after meeting with numerous money managers who expressed their urgent need for real-world, effective compliance solutions.  Our staff is well known in the industry for building leading compliance solutions.  The products our staff has produced continue to be rated #1, as shown by a recent Ernst & Young compliance survey.

Our engineers have built solutions for the largest to the smallest mutual funds; from individual firms to outsourcing firms having dozens of clients.  We understand that each clients' business has unique requirements and that a "one size fits all" approach doesn't always work.  We are tireless and tenacious in building the best products possible and in providing world class, friendly and knowledgeable service.  Our customers are our strongest advocates.

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Each month, we present a topic of interest related to portfolio compliance or aggregate monitoring.  As compliance regulations often require interpretation, the "Compliance Issue of the Month" helps our clients benefit from one another's perspective.  When responding to the survey below, please answer only once.  Also, make sure you have added your email address above to receive a copy of the results when published.

An ADR represents ownership of shares in a non-U.S. company.  ADRs are traded in the U.S. and are dollar denominated.  The structure of an ADR includes a ratio, which determines how many shares in the non-U.S. company are represented by one ADR.  For example, a single Volkswagen ADR represents one fifth of a share of Volkswagen German stock.

Understanding the structure and meaning of ADRs can be important for compliance testing.  An ADR is a U.S. instrument, but represents foreign issued shares, so a careful review of your security master reference database may be in order to double check the country information for each ADR.

For issuer and country exposure tests, how you consider an ADR may be different depending on the compliance rule being checked.  For instance, Germany considers owning ADRs to be equivalent to owning the underlying security, but Japan and Hong Kong don't.

Consider the following:  You have a Japanese equity fund that holds Sony shares directly and you have a US equity fund that holds Sony ADRs.  When performing industry, country, and other concentration tests, in some cases you want to "look through" the ADR to the underlying security, in other cases you don't.  Also to be considered are the multicurrency issues, the type of the ADR, the ADR ratio, and the fact that the ADR and underlying security have different CUSIPs/SEDOLs/ISINs, etc.

Japan does not recognize the holders of ADRs as having the voting rights of the underlying security, instead these rights are held by the custodian.  How you treat the ADR depends on the both the rule and the jurisdiction (for instance, concentrations in Japanese ITA versus SEC).