Information Walls are internal methods used to ensure that information gained while acting for one client does not leak to people in another part of the same firm who are acting for another client to whom that information may be highly relevant. The principal aims are to protect client confidentiality and to ensure fair treatment of all clients. There are a variety of different procedures for achieving this, for example, locked rooms for relevant documents, separate teams working on the different sides to the matter, written rules on maintaining confidentiality and restricted access to certain parts of a building and monitoring of those who enter those areas.
A restricted list is a list of issuers whose securities or other financial instruments are subject to restrictions on sales, trading, or research activity. The restricted list reinforces your controls around protecting confidential information. It prevents situations such as the purchase by investment managers of a firm of shares in a company just before the merchant banking arm of that firm launches a takeover bid for that company.
When an issuer appears on the restricted list, certain sales, trading and research activities involving that issuer ’s securities or other financial instruments may be restricted. Obviously issuers should only be added to the restricted list after information is no longer price sensitive. Whilst the information is price sensitive you should consider using a watch list.
This template gives you a template for you to managed your own Restricted List. It is set up so that your own maintenance is as limited and simple as possible. We include drop down menu’s with clear guidance on what those restrictions mean. We have even done the thinking for you of which teams and departments might need different types of restriction.
There are worked examples in the template showing you what it could look like once you add in different instruments and scenarios. We explain the scenarios, and use notes in the template to explain why you might want to restrict some areas of the business and not others.
The Restricted List template covers:
- The template restricted list
- Instructions on its use
- Guidance on what restrictions actually mean in practice
- Worked examples
This Restricted List template incorporates regulatory expectations, best practice and looks to enable smaller firms to follow best practice with limited administrative burden. It is designed for use by Compliance or the Control Room. We know those individuals may not necessarily have the bandwidth or regulatory experience to know what they must cover so we have done that for you.
The template has been designed with the Compliance Officer in mind, making it practical, succinct, and self explanatory with drop down menu’s for you to record your restrictions.
The template includes notes for the individual that will manage the restricted list which include instructions on how to amend the drop down menu’s to reflect internal risk appetite and approach.
As with all our templates this has been formatted ready to print and \ or circulate internally. It is ready for you to apply your corporate branding or just start using.
This template should be relatively straightforward for someone outside the UK, and not familiar with the UK regime, to follow and put into use.
Restricted List Template
This document is in Microsoft Excel (*.xlsx) format