Razak, 37, CEO of CIMB Malaysia, says he tries to emulate U.S. investment-bank management styles.
He was one of the first managers in Malaysia to reward successful staffers with fat yearend bonuses.
(His own reward: 38 million CIMB shares, or 4.4%, worth $55 million.)
That means working New York-style hours, too. "CIMB has a reputation for being a very hard place to work," he concedes. But those long days are paying off.
http://www.businessweek.com/magazine/content/04_28/b3891423.htm
Issues in bonus payment systems.
I came across this issue in Mint of 12 May 2008 (page 20). The item is a reprint from Wall Street Journal.
Jeffrey Liddle, an attorney in New York, says he filed an arbitration claim this week on behalf of a former mortgage-backed securites saleman at Merrill Lynch & Co. Despite having his best year ever, the saleaman's pay plummeted to about $190,000 from $1.2 million.
"He couldn't make enouhg money to feed his family," Mr Liddle says. The employee asked to be laid off, so he could receive a severance package. Merrill Lynch declined, so the salesman quite and took a job as a stockbroker at another firm.
How could it happen?
Monday, May 12, 2008
Friday, May 9, 2008
Goldman Sachs University
At Goldman Sachs, there are no less than 2,000 training programmes available delivering training that encompasses everything from products and market knowledge, leadership and management, professional skills, to diversity and inclusion awareness. It becomes apparent that the term 'university' is rather apt – for what is on offer is a universal education designed to ensure that Goldman staff are best of breed.
At Goldman, senior business leaders are the teachers and professors. Osmond tells me that the chiefs and head honchos regularly take time out of their schedule to run a training event or teach a methodology – whether it relates to leadership or equity valuation. This does result, admits Osmond, in a leaning towards in-house training as the favoured method but it's something they are proud of and Osmond believes it is important: "The Goldman focus is very contextual."
Client training has grown nearly 10-fold in five years as word has spread within Goldman and to its clients.
Last year (2007) the bank won the Best for Training & Development Award in The Sunday Times' annual Best Companies Awards for a large company.
http://www.trainingzone.co.uk/cgi-bin/item.cgi?id=179461
At Goldman, senior business leaders are the teachers and professors. Osmond tells me that the chiefs and head honchos regularly take time out of their schedule to run a training event or teach a methodology – whether it relates to leadership or equity valuation. This does result, admits Osmond, in a leaning towards in-house training as the favoured method but it's something they are proud of and Osmond believes it is important: "The Goldman focus is very contextual."
Client training has grown nearly 10-fold in five years as word has spread within Goldman and to its clients.
Last year (2007) the bank won the Best for Training & Development Award in The Sunday Times' annual Best Companies Awards for a large company.
http://www.trainingzone.co.uk/cgi-bin/item.cgi?id=179461
Can a Universal Bank be a Trusted Advisor?
Read
Ben Stein vs. Goldman Sachs: Market-Makers, Brokers, and Trusted Advisors
by Charles H. Green posted on Tuesday, December 4, 2007
http://trustedadvisor.com/trustmatters/277/Ben-Stein-vs-Goldman-Sachs--Market-Makers--Brokers--and-Trusted-Advisors
Ben Stein vs. Goldman Sachs: Market-Makers, Brokers, and Trusted Advisors
by Charles H. Green posted on Tuesday, December 4, 2007
http://trustedadvisor.com/trustmatters/277/Ben-Stein-vs-Goldman-Sachs--Market-Makers--Brokers--and-Trusted-Advisors
Sunday, May 4, 2008
Compliance courses - UK
http://www.deltacompliance.co.uk/Default.aspx?page=420
E-Learning
Innovation from compliance & elearning experts
Benefit from the largest range of compliance courses in the market.
Obtain an optimal solution of compliance expertise and cutting edge elearning solutions, delivering a library of over 30 courses, all of which can be easily customised to suit your policies and culture.
Access to the elearning courses is for one year and you can access the courses as many times as you like. The course will bookmark, so if you only get part-way through any course, you can next time either start from the beginning, or start from where you left off.
All of the online courses are written by compliance experts, designed by ISO 9001-accredited instructional design experts, tailored free of charge and provide user tracking and real-time feedback. Other innovations include structured learning paths, pre-testing for course personalisation, refresher modules, expected performance scores and competency mapping.
Course list
Anti-Money Laundering for Asset Managers
Anti-Money Laundering for Building Societies
Anti-Money Laundering for Financial Advisors
Anti-Money Laundering for Investment Banks
Anti-Money Laundering for Private Banks
Anti-Money Laundering for Stockbrokers
Anti-Money Laundering for The US
Anti-Money Laundering Global Edition
Approved Persons
Client Assets
COB: Accepting Customers
COB: Advising and Selling
COB: Dealing and Managing
COB: Financial Promotions
COB: Trustee and Depositary Activities
Code of Inter-Professional Conduct
Code of Market Conduct
Complaints Handling
Conduct of Business Standards
Data Protection
Ethics: Fundamental Responsibilities
Ethics: Responsibilities to Clients
Ethics: Responsibilities to Employer
Fraud Prevention
How the FSA Works
Introduction to UK Regulation
Market Abuse Regime
Personal Account Dealing
Price Stabilising Rules
Racial Discrimination
Senior Management Arrangements,
Systems and Controls
Sexual Discrimination
Training and Competence
Phone: to order over the phone call Compliance Online Sales on 020 7083 7200 and discuss your requirements. We will send you an invoice by email, fax or post.
Email: to order by email, email training@complianceonline.co.uk and we send you an order form for you to print and fax or post back.
E-Learning
Innovation from compliance & elearning experts
Benefit from the largest range of compliance courses in the market.
Obtain an optimal solution of compliance expertise and cutting edge elearning solutions, delivering a library of over 30 courses, all of which can be easily customised to suit your policies and culture.
Access to the elearning courses is for one year and you can access the courses as many times as you like. The course will bookmark, so if you only get part-way through any course, you can next time either start from the beginning, or start from where you left off.
All of the online courses are written by compliance experts, designed by ISO 9001-accredited instructional design experts, tailored free of charge and provide user tracking and real-time feedback. Other innovations include structured learning paths, pre-testing for course personalisation, refresher modules, expected performance scores and competency mapping.
Course list
Anti-Money Laundering for Asset Managers
Anti-Money Laundering for Building Societies
Anti-Money Laundering for Financial Advisors
Anti-Money Laundering for Investment Banks
Anti-Money Laundering for Private Banks
Anti-Money Laundering for Stockbrokers
Anti-Money Laundering for The US
Anti-Money Laundering Global Edition
Approved Persons
Client Assets
COB: Accepting Customers
COB: Advising and Selling
COB: Dealing and Managing
COB: Financial Promotions
COB: Trustee and Depositary Activities
Code of Inter-Professional Conduct
Code of Market Conduct
Complaints Handling
Conduct of Business Standards
Data Protection
Ethics: Fundamental Responsibilities
Ethics: Responsibilities to Clients
Ethics: Responsibilities to Employer
Fraud Prevention
How the FSA Works
Introduction to UK Regulation
Market Abuse Regime
Personal Account Dealing
Price Stabilising Rules
Racial Discrimination
Senior Management Arrangements,
Systems and Controls
Sexual Discrimination
Training and Competence
Phone: to order over the phone call Compliance Online Sales on 020 7083 7200 and discuss your requirements. We will send you an invoice by email, fax or post.
Email: to order by email, email training@complianceonline.co.uk and we send you an order form for you to print and fax or post back.
Goldman Sachs Management Policies
CODE OF BUSINESS CONDUCT AND ETHICS
http://www2.goldmansachs.com/our-firm/investors/corporate-governance/corporate-governance-documents/code-of-business-conduct-ethics.pdf
Goldman Sachs Environmental Policy Framework
http://www2.goldmansachs.com/citizenship/environment/policy-framework.pdf
Goldman Sachs JBwere asset management details of trade management policies
http://www.gsjbw.com/documents/productsandservices/managedfunds/GSJBWAM_Trade_Management_Policies.pdf
Privacy
Goldman Sachs JBWere Group Privacy Statement
http://www.gsjbwere.com/Help/default.cfm?p=H_PrivPoli
https://www.gsfundadmin.com/goldman/goldmanJump/me.get?DPS.organizations.page&PRIVACY&SESSION_MENU=0
Compliance Problems
September 4 2003, Transaction in 30 year US govt bonds
http://www.sec.gov/litigation/admin/34-48436.htm
http://www2.goldmansachs.com/our-firm/investors/corporate-governance/corporate-governance-documents/code-of-business-conduct-ethics.pdf
Goldman Sachs Environmental Policy Framework
http://www2.goldmansachs.com/citizenship/environment/policy-framework.pdf
Goldman Sachs JBwere asset management details of trade management policies
http://www.gsjbw.com/documents/productsandservices/managedfunds/GSJBWAM_Trade_Management_Policies.pdf
Privacy
Goldman Sachs JBWere Group Privacy Statement
http://www.gsjbwere.com/Help/default.cfm?p=H_PrivPoli
https://www.gsfundadmin.com/goldman/goldmanJump/me.get?DPS.organizations.page&PRIVACY&SESSION_MENU=0
Compliance Problems
September 4 2003, Transaction in 30 year US govt bonds
http://www.sec.gov/litigation/admin/34-48436.htm
Access to US Market for Foreign Investment Advisors
U.S. Open Market for Foreign Advisers
It is relatively easy for a foreign adviser to register as an investment adviser in the United States and to set up its own U.S. mutual funds. An adviser, including any foreign adviser that wants to manage a registered mutual fund in the United States, may register as an investment adviser under the Investment Advisers Act of 1940. It is no more difficult for a foreign adviser to register than for a domestic adviser to register under the Advisers Act. There are very few barriers to entry for investment advisers wishing to register in the United States. There are no residency requirements. Thus, an adviser can be located outside the United States and is not required to establish a U.S. subsidiary in order to register as an investment adviser in the United States. There are no minimum educational requirements, and there are no capital requirements for investment advisers, although advisers that sponsor a registered mutual fund must make sure that fund has the requisite seed money of $100,000.
The main barrier to registration as an investment adviser in the United States would be if the adviser had been the subject of certain disciplinary actions. I understand that some other regulatory jurisdictions follow a different approach for investment advisers, conducting a pre-approval merit review of those that want to sponsor a fund or manage money in a jurisdiction to ensure that they are "fit and proper" or meet similar regulatory standards.
Many foreign advisers are exempt from registration as advisers in the United States if they have 14 or fewer U.S. clients, do not hold themselves out to the U.S. public as an investment adviser and do not serve as an adviser to an investment company registered under the Investment Company Act.
The Advisers Act and its rules make certain accommodations for foreign advisers. In determining whether an adviser qualifies for the 14 or fewer clients exception from the definition of investment adviser, foreign advisers are permitted to count only U.S. clients, while U.S. advisers must count all clients. However, if a foreign adviser chooses, or is required, to register in the United States, it may do so with the Commission, regardless of the amount of assets it has under management. NSMIA amended the Investment Advisers Act so that advisers with $25 million or more in assets under management generally register with Commission, and advisers with less than $25 million generally register with the states. However, all advisers with principal offices outside the United States register with the Commission rather than the states, and this single regulator approach eases some administrative difficulties for foreign advisers. Additionally, although the Advisers Act places certain restrictions on advisory contracts, including limitations on performance fees, the Advisers Act excepts contracts with persons who are not U.S. residents. Congress added this exception in NSMIA, recognizing that the common use of performance fee arrangements in other countries placed U.S.-registered advisers operating in foreign countries at a competitive disadvantage.
http://www.sec.gov/news/speech/spch552.htm
It is relatively easy for a foreign adviser to register as an investment adviser in the United States and to set up its own U.S. mutual funds. An adviser, including any foreign adviser that wants to manage a registered mutual fund in the United States, may register as an investment adviser under the Investment Advisers Act of 1940. It is no more difficult for a foreign adviser to register than for a domestic adviser to register under the Advisers Act. There are very few barriers to entry for investment advisers wishing to register in the United States. There are no residency requirements. Thus, an adviser can be located outside the United States and is not required to establish a U.S. subsidiary in order to register as an investment adviser in the United States. There are no minimum educational requirements, and there are no capital requirements for investment advisers, although advisers that sponsor a registered mutual fund must make sure that fund has the requisite seed money of $100,000.
The main barrier to registration as an investment adviser in the United States would be if the adviser had been the subject of certain disciplinary actions. I understand that some other regulatory jurisdictions follow a different approach for investment advisers, conducting a pre-approval merit review of those that want to sponsor a fund or manage money in a jurisdiction to ensure that they are "fit and proper" or meet similar regulatory standards.
Many foreign advisers are exempt from registration as advisers in the United States if they have 14 or fewer U.S. clients, do not hold themselves out to the U.S. public as an investment adviser and do not serve as an adviser to an investment company registered under the Investment Company Act.
The Advisers Act and its rules make certain accommodations for foreign advisers. In determining whether an adviser qualifies for the 14 or fewer clients exception from the definition of investment adviser, foreign advisers are permitted to count only U.S. clients, while U.S. advisers must count all clients. However, if a foreign adviser chooses, or is required, to register in the United States, it may do so with the Commission, regardless of the amount of assets it has under management. NSMIA amended the Investment Advisers Act so that advisers with $25 million or more in assets under management generally register with Commission, and advisers with less than $25 million generally register with the states. However, all advisers with principal offices outside the United States register with the Commission rather than the states, and this single regulator approach eases some administrative difficulties for foreign advisers. Additionally, although the Advisers Act places certain restrictions on advisory contracts, including limitations on performance fees, the Advisers Act excepts contracts with persons who are not U.S. residents. Congress added this exception in NSMIA, recognizing that the common use of performance fee arrangements in other countries placed U.S.-registered advisers operating in foreign countries at a competitive disadvantage.
http://www.sec.gov/news/speech/spch552.htm
Access to US Market for Foreign Mutual Funds
In 1998, it was estimated that over 14% (or $980 billion) of U.S. mutual fund assets are managed by foreign advisers or their U.S. affiliates. Certainly, foreign advisers have been able to make significant inroads in the U.S. market, but there are certain barriers.
Section 7(d) of the Investment Company Act
Section 7(d) has prevented foreign advisers from directly offering their foreign funds to a large number of U.S. investors. Under Section 7(d), only funds organized under the laws of the United States, or any state, are permitted to offer shares in the United States. However, Section 7(d) authorizes the Commission to issue orders permitting foreign-organized funds to offer shares in the United States if the Commission finds that, by reason of special circumstances or arrangements, it is both legally and practically feasible effectively to enforce the provisions of the Investment Company Act against the foreign fund and that permitting the foreign fund to offer shares in the United States is consistent with the public interest and the protection of investors. Thus, Section 7(d) ensures that U.S. investors receive the same essential investor protection whether they acquire shares in a foreign fund or U.S.-organized fund. Many foreign funds are unwilling to submit to having all provisions of the Investment Company Act imposed on them. In fact, only 19 foreign funds, most of them from Canada, have ever received orders under Section 7(d). The SEC issued the last such order in 1973.
Section 7(d) is statutory rule. Therefore, an amendment to Section 7(d) requires an act of the U.S. Congress.
In practice, however, the requirements of Section 7(d) have not posed a problem for foreign fund managers in penetrating the U.S. market. Many foreign fund managers have responded by acquiring U.S. investment management organizations or by setting up their own U.S. affiliates. A foreign investment manager may organize and register a U.S. mutual fund to be sold in the United States on the same basis as a U.S. investment manager. Moreover, it is relatively easy for a foreign firm to establish funds in the United States to replicate an existing foreign fund, which can be managed and administered outside the United States.
The SEC has shown flexibility in permitting performance information, such as that of a comparable foreign fund, to be included in prospectuses of the U.S. funds, greatly aiding foreign managers in marketing their U.S. funds. Also, the National Securities Markets Improvement Act of 1996 ("NSMIA") facilitated a true national market in the United States, eliminating substantive regulation of mutual funds by states, making it considerably easier for foreign firms to access the U.S. markets.
It should also be noted that Section 7(d), as interpreted by the Division of Investment Management, does not prohibit private offerings of foreign funds to U.S. residents, as long as those offerings comply with the private offering requirements of the U.S. securities laws. Section 3(c)(1) of the Investment Company Act provides an exemption for privately placed funds with fewer than 100 beneficial owners and Section 3(c)(7) provides an exemption for privately placed funds sold exclusively to "qualified purchasers." The SEC staff has been flexible in interpreting these provisions, taking the position that a foreign fund may make a private U.S. offering under these exemptions concurrently with an offshore public offering. (See Goodwin, Procter & Hoar, (pub. avail. Feb. 28 1997); Touche Remnant & Co. (pub. avail. August 27, 1984)). Moreover, we have confirmed that a foreign fund remains eligible for these exclusions so long as it has 100 or fewer U.S. persons as beneficial owners or has U.S. investors who are qualified purchasers, regardless of the number or sophistication of its non-U.S. investors. (Goodwin, Procter & Hoar (pub.avail. Feb. 28, 1997)). I should also note that the SEC staff has permitted foreign funds to exceed the 100 U.S. beneficial owner limit or to have U.S. investors who are not qualified purchasers if this is as a result of independent actions of the fund's security holders. (Investment Funds Institute of Canada (pub. avail. March 4, 1996)).
US law insists on independent director in the mutual fund. But,With respect to independent directors of U.S. mutual funds, that there is no residency requirement for directors. Thus, a foreign fund manager could establish a U.S. fund that has a board of all non-U.S. directors. In addition, there are several other areas where the Investment Company Act does not impose requirements in contrast to other countries. For example, the Investment Company Act does not impose high capital, staffing, residency or U.S. place of business requirements so that a U.S. registered fund can be administered outside of the United States.
http://www.sec.gov/news/speech/spch552.htm
Section 7(d) of the Investment Company Act
Section 7(d) has prevented foreign advisers from directly offering their foreign funds to a large number of U.S. investors. Under Section 7(d), only funds organized under the laws of the United States, or any state, are permitted to offer shares in the United States. However, Section 7(d) authorizes the Commission to issue orders permitting foreign-organized funds to offer shares in the United States if the Commission finds that, by reason of special circumstances or arrangements, it is both legally and practically feasible effectively to enforce the provisions of the Investment Company Act against the foreign fund and that permitting the foreign fund to offer shares in the United States is consistent with the public interest and the protection of investors. Thus, Section 7(d) ensures that U.S. investors receive the same essential investor protection whether they acquire shares in a foreign fund or U.S.-organized fund. Many foreign funds are unwilling to submit to having all provisions of the Investment Company Act imposed on them. In fact, only 19 foreign funds, most of them from Canada, have ever received orders under Section 7(d). The SEC issued the last such order in 1973.
Section 7(d) is statutory rule. Therefore, an amendment to Section 7(d) requires an act of the U.S. Congress.
In practice, however, the requirements of Section 7(d) have not posed a problem for foreign fund managers in penetrating the U.S. market. Many foreign fund managers have responded by acquiring U.S. investment management organizations or by setting up their own U.S. affiliates. A foreign investment manager may organize and register a U.S. mutual fund to be sold in the United States on the same basis as a U.S. investment manager. Moreover, it is relatively easy for a foreign firm to establish funds in the United States to replicate an existing foreign fund, which can be managed and administered outside the United States.
The SEC has shown flexibility in permitting performance information, such as that of a comparable foreign fund, to be included in prospectuses of the U.S. funds, greatly aiding foreign managers in marketing their U.S. funds. Also, the National Securities Markets Improvement Act of 1996 ("NSMIA") facilitated a true national market in the United States, eliminating substantive regulation of mutual funds by states, making it considerably easier for foreign firms to access the U.S. markets.
It should also be noted that Section 7(d), as interpreted by the Division of Investment Management, does not prohibit private offerings of foreign funds to U.S. residents, as long as those offerings comply with the private offering requirements of the U.S. securities laws. Section 3(c)(1) of the Investment Company Act provides an exemption for privately placed funds with fewer than 100 beneficial owners and Section 3(c)(7) provides an exemption for privately placed funds sold exclusively to "qualified purchasers." The SEC staff has been flexible in interpreting these provisions, taking the position that a foreign fund may make a private U.S. offering under these exemptions concurrently with an offshore public offering. (See Goodwin, Procter & Hoar, (pub. avail. Feb. 28 1997); Touche Remnant & Co. (pub. avail. August 27, 1984)). Moreover, we have confirmed that a foreign fund remains eligible for these exclusions so long as it has 100 or fewer U.S. persons as beneficial owners or has U.S. investors who are qualified purchasers, regardless of the number or sophistication of its non-U.S. investors. (Goodwin, Procter & Hoar (pub.avail. Feb. 28, 1997)). I should also note that the SEC staff has permitted foreign funds to exceed the 100 U.S. beneficial owner limit or to have U.S. investors who are not qualified purchasers if this is as a result of independent actions of the fund's security holders. (Investment Funds Institute of Canada (pub. avail. March 4, 1996)).
US law insists on independent director in the mutual fund. But,With respect to independent directors of U.S. mutual funds, that there is no residency requirement for directors. Thus, a foreign fund manager could establish a U.S. fund that has a board of all non-U.S. directors. In addition, there are several other areas where the Investment Company Act does not impose requirements in contrast to other countries. For example, the Investment Company Act does not impose high capital, staffing, residency or U.S. place of business requirements so that a U.S. registered fund can be administered outside of the United States.
http://www.sec.gov/news/speech/spch552.htm
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