1) As Head of Compliance for Belgium & Senior Compliance Officer, what is proving to be the main focus in your role currently at NN Investment Partners?
Besides general compliance items on personal conduct such as personal account dealing and gift and entertainment policies and business conduct such as product development and marketing, my main focus lies with the Front Office portfolio management and trading activities and with managing the potential conflicts between our proprietary and third party book. Related to these focus areas I am directly involved in our information barriers (Chinese walls), trading and allocation policies, error handling and market abuse policies and procedures.
2) The Market Abuse Regulation (MAR) is a complex directive. How can an efficient relationship between compliance and the portfolio managers ease the ‘pain’?
We have an open and direct relationship with the Central Trading Desk, senior management of the Front Office and a lot of the individual portfolio managers with whom we actively discuss changes of regulations and the practical impact to our business. In this way we try to make sure that beside complying with the regulations, our policies and procedures connect to the daily practice and our employees understand why certain choices are/need to be made.
3) Why has PRIIPs become less of a burden for the business in recent months?
Of course it is still to see how it develops, but on the short term it will be possible to make more use of existing data already available within the organisation for the KID than originally expected and therefore we have more time to develop towards the future, then knowing what the final detailed standards will be.
4) From a buy-side perspective – how do you feel that the role of the sell-side in regulatory compliance has changed?
Especially on the MAR and then specifically around Market Soundings you see much more attention by the sell side on sharing potential inside information than in the past, which also makes lives for the buy-side compliance more clear and therefore easier.
5) How do you think the regulatory landscape in Europe (and further afield!) will continue to develop in the next few years? Will the burden increase?
You slowly see a decrease in the speed of new legislation, but it still will take time to find a new balance. Of course the ideas behind a lot of the regulations were solid and understandable, but hopefully new future legislation will be more to align the different recently implemented regulations.