The obligations imposed by the 2016 Market Abuse Regulation (MAR) may seem an onerous new burden, yet Singletrack’s MAR investment recommendations module is proving to be an easily implemented and comprehensive answer for sell-side firms.
In essence, MAR demands total transparency in all aspects of investment recommendation. Market abuse is defined by MAR as ‘a concept that encompasses unlawful behaviour’, which includes such issues as insider dealing, unlawful disclosure of inside information and market manipulation.
Therefore MAR requires all persons who produce or disseminate investment recommendations to objectively present information, and effectively disclose interests or conflicts of interest.
…Singletrack’s workable solution
Singletrack’s MAR module holds a recommendations database which seamlessly integrates with the Singletrack Edge CRM platform to record new recommendations, at the start of the day or as client activities are logged. Within every recommendation, the module captures the following information:
- Date (completion date)
- Target price
- Market price
- Time horizon
- Conflicts of interest
- Recommendation comments
In accordance with MAR guidelines, additional key data can be captured at the time of dissemination – to include investment recommendation, analyst recommendation, set recommendation and market price (at the time of dissemination).
Practical, useable, effective
When recommendations are made over the phone or in a meeting, the data can be captured by Singletrack Call Manager or in an activity logging sidebar. Users can view a list of all their recommendations, and also view or amend recommendations already associated with a client activity.
Clients share this view – be it through recommendation history displayed on an investor-facing web page, or via daily extracts displayed at close of business. A link to the history can be embedded in any client communication.
A demonstration of intent
Banks and brokers implementing the Singletrack MAR module are demonstrating a clear commitment to compliance. It indicates to the regulator that they are meeting MAR’s core requirements, having demonstrably taken several steps towards compliance, and have a framework in place to embrace further obligations as the details emerge.
MAR obligations in brief
- All projections, forecasts and price targets need to be clearly labelled with an indication of all material assumptions made in producing or using them
- Detailed information about the valuation or methodology and the underlying assumptions to be directly and easily accessible
- The meaning of any investment recommendation (i.e. Buy, Sell, Hold) and the period of time it applied must be adequately explained, together with any associated risk
- Planned frequency of updates, and indications of the relevant date and time for any prices of related financial instruments and where the recommendation differs from previous recommendations during the last 12 months
Singletrack Edge CRM – an overview
- A dedicated sell-side CRM, client engagement and research monetisation platform
- Provides the intelligence to monitor, manage and plan revenue generating activities on a fully coordinated, cross-departmental basis
- Delivers maximum visibility and control, with the flexibility to meet individual user firm’s requirements
- Purpose-designed for an increasingly competitive and regulated environment
Singletrack was founded in London’s financial centre in 2009 by a former JPMorgan CTO who saw the potential in applying on-demand technology and advanced analytics to sell-side customer engagement and research distribution. Today the company supplies a range of capital markets CRM, client engagement and research monetisation solutions backed by a proven best practice methodology. The company’s products are used by investment banks, institutional brokers and independent research providers on four continents.