Let me introduce myself, my name is Angie Huff and if you are reading this then the chances are that I have been in your position at some point during my career.
I started my career at UBS investment bank in 2000. When I first started in shareholding disclosures there were no vendors in the market offering a solution and accessing the rules globally was a particular challenge. Our team compiled the disclosures not only for the investment bank but also on behalf of the asset management and private wealth management arm of the parent company. At this point I did not really understand what the different derivatives were, which of these derivatives should be included in the calculation or the different ways you could have exposure to shares and derivatives. There was very little information in the market to help with this and no training courses. It was difficult internally calculating the global positions across such a large organisation.
Meeting the strict disclosure deadlines was a significant challenge. I faced many of the issues you have probably faced or are facing; regulatory enquiries/ investigations, sanctions, internal audits, reporting to the Board, issues with tripping a sensitive industry threshold, coping with a manual process, building out a global solution and interpreting legal rules and much more.
Takeover Directive and Transparency Directive
During my time at UBS there was considerable change in the world of shareholding disclosures with the European implementation of the Takeover Directive and the Transparency Directive. Whilst it was initially welcomed as it was believed this would harmonise shareholding rules across Europe, sadly this was not in fact the case. As directives and not regulation, there remained many variations in the shareholding rules from country to country. It also meant that I had to personally face the challenge of implementing all these rules within a short timeframe. I think we’ve probably all been there – many long days and nights in the office scrambling to find a solution to complying with the new rules!
In 2007 I was head-hunted by Morgan Stanley, then later by Barclays Capital and finally Deutsche Bank. I faced many of the same challenges at each organisation and throughout my collaborations with peer banks, it became clear this was an industry-wide issue.
At Morgan Stanley I faced the challenge in 2008 (in the midst of the financial crisis) of the overnight (and I mean literally overnight) introduction of net short position disclosures. It was a very challenging time as these were introduced without warning, there was no consultation, no FAQs, and no real detail on how to comply, but it was clear that immediate compliance was expected. There was no such short disclosure requirement before this time, therefore our systems and processes were not set up to handle such different calculations.
I remember sitting at home on the weekend with Google alerts set up, so that I was immediately aware of those other countries who introduced a similar short position disclosure requirement over that fateful weekend. Myself, my team and our IT department worked around the clock to ensure that we complied with the rules.
Working with aosphere
It was during my time at Morgan Stanley that I had conversations with an affiliate of Allen & Overy called aosphere and joined their advisory board to opine on the needs in this area for the financial services industry. It was a fantastic collaboration with a few others in the industry and out of this was born their shareholding disclosure Rulefinder service. Kaizen’s Shareholding Disclosure Service uses this as a basis to our rules library in the service we offer. This offering from aosphere made a real difference to me and the industry. We finally had one place where we could access shareholding rules globally. However, to truly apply this to your business and positions you needed considerable understanding of many factors including derivative products, methods of trading/holding positions, corporate structures, and legal and industry terminology. And there was still another thing missing – a system solution to the shareholding disclosure challenge.
At Barclays Capital I faced another challenge of managing this area globally and at Deutsche Bank I had the challenge of implementing the changes in the German rules shortly after my arrival with little lead time which again meant many hours spent in the office.
Challenges I’ve faced
Throughout my career I have faced many challenges including implementing solutions internally, looking for vendors (many of whom didn’t have any direct experience at the coal face), dealing with the issues resulting from human error with a manual process, answering regulatory enquiries, dealing with the fall-out of regulatory sanctions and reading and implementing the rules myself (where my law degree did come in handy). You cannot really work in shareholding disclosures without becoming heavily involved in data. Each financial institution has their own data issues and nuances. Market data is also another challenge for shareholding disclosures which has to be taken into consideration in any monitoring and reporting solution.
All of these challenges really shaped me and gave me greater insight into the needs of those within shareholding disclosure compliance/operations teams.
A new start as an entrepreneur
In 2013 I left the industry to become an entrepreneur and build a solution for all my peers in the shareholding disclosure space. I worked closely with Adam Stearn, our technical architect and lead developer, to design and build a system incorporating solutions to all the problems I had met along the way. Adam has 19 years’ experience in designing and implementing complex data processing systems and has a background in military IT projects and with that, a real understanding of the security required by our clients.
In your shoes
My 13 years’ of in-house shareholding disclosure compliance experience has been applied to every part of our service to make life simple for you. I truly understand those deadlines and how important it is to quickly react to regulatory change. With our service you can be rest assured that we understand the challenges you are facing.
Our aim is to take away the pain and stress of shareholding disclosures, to streamline the process, to make compliance with the rules globally simple and make reacting to regulatory change a fast and simple experience.
With our integration with Kaizen we can really leverage their multi-award winning services and technologies to further improve the service for our clients.
We offer more than just a system within our service – we have genuine expertise of sitting where you are. For more information about our Shareholding Disclosure Service or to watch our short introductory video, visit our SDS service page.
For a demonstration of the system or a conversation with Angie Huff, please contact us.