Monthly Archives: January 2015

Category: Blue Sky, Compliance

Why Does Blue Sky Compliance Remind Me of the IRS?


statesFocus on compliance has elevated within fund boards, and a fairly recent hot topic has been compliance with state Blue Sky laws and regulations. Blue Sky related expenses are receiving increased attention as a direct result of the fact that a number of states have increased their notice filing fees during the past five years. But let’s understand what Blue Sky compliance represents and try to answer the question – is it more like something from the SEC or the IRS?

Back in 1911, Kansas created the first Blue Sky laws to protect its citizens from con men disguised as investment professionals. Similar to current laws, securities needed to be registered with the state prior to sale. The states would review the prospectus and in some cases request changes if the state examiner determined information was unclear or misleading. Once the state examiner determined the security met the standards for the state, registration was granted. There were fees associated with this initial examination and fees to renew the registrations.

Then something happened along the way, The National Securities Markets Improvement Act of 1996. This amendment to federal securities law preempted the states’ securities regulations.  Translation: the individual states could no longer require federally-covered securities, like mutual funds, to be registered. Sounds like a free pass, right?  Wrong, here is where my IRS comparison comes in. The states were allowed to require a notice filing, which means you are not actually registering, but giving notice of intent to offer or sell in the state. So the state can no longer examine your filing to determine your qualification to register, which is done by the SEC, but they can require you to give notice – and pay a fee to do so. Is this starting to sound like a revenue collection agency?

Every state has unique Blue Sky laws and regulations. Fortunately, the majority of the states do not require sales reporting. It is for the remaining twenty-two states that base notice filing fees on sales that we must begin to think like tax accountants and find exemptions to reduce the amount of sales reported.  The keys to a robust Blue Sky compliance program include determining your level of risk, understanding the sources of your sales, researching exemption criteria, and documenting your decisions. Short of not offering your funds, it is impossible to avoid paying state fees, but with planning there may be opportunities to lower them.

Category: Associate Development and Engagement, Conferences and Events

What do you want to be when you grow up?


Every year a number of Boston Financial associates attend the Massachusetts Conference for Women. Being the largest conference of its kind in the country, the event hosts a number of prestigious speakers and packs a full agenda of educational break-out sessions.

This is the fourth in a series of blog posts recapping the experiences our associates had at the event.


successWhat do you want to be when you grow up? That’s a question kids around the world are asked every day. The answers usually range from astronaut to police officer and veterinarian to teacher. Do you remember what you wanted to be when you were 6? Though your dream job has probably changed since then, you should still think big and go for it. Easier said than done, right?

Year after year, our associate survey at Boston Financial shows that our employees want to continuously develop, learn, and grow. Many companies, like Boston Financial, play a part in satisfying that need by offering programs that support professional development. However, you are responsible for your own career path. You are the driving force behind your success. Are you going for it?

On December 10, I had the privilege of listening to the Academy Award winning actress Lupita Nyong’o at the Massachusetts Conference for Women. Nyong’o provided her perspective on how to achieve your dreams and get to where you want to be. I was struck by Nyong’o’s humility. She was so appreciative of her success, but it was also clear that she worked hard to get where she is. For Nyong’o, every achievement lays the groundwork for the next step in her journey.

Nyong’o believes that goals should be big, seemingly unachievable and out of reach. To make the journey to achieving these goals less daunting and hopeful, she provided the following advice:

  • Articulate your goal to yourself and write your dreams on paper- don’t underestimate the power this has. Writing your thoughts on paper make them real. Be specific and describe what you want so you can set a clear path to get there. Define your measure of success.
  • Recognize the fear- fear can stop you in your tracks. Don’t let it. Embrace it and use it to set your plan.
  • Reach out to your advocates- talk about your fears to the people who support you. Lean on your mentors, managers, family, and friends; they can talk you out of your fears. Talking it through will help you keep moving toward your goals.
  • Ask yourself questions and listen for the answers all around you.
  • Breath and meditate – be still with your thoughts and feelings.
  • Allow failure to be an option- don’t let the fear of failure stop you. Go for it!
  • Step forward and repeat it all!

As you progress through your career, don’t miss out on opportunities. Take risks and learn new lessons. Getting to success by learning and growing will always be hard work. It may never get comfortable, but if you keep at it, it will become familiar. So go for it, opportunities are waiting for you!

Category: Associate Development and Engagement, Conferences and Events

Looking to Transform in 2015? Check Your Lens First


Every year a number of Boston Financial associates attend the Massachusetts Conference for Women. Being the largest conference of its kind in the country, the event hosts a number of prestigious speakers and packs a full agenda of educational break-out sessions.

This is the third in a series of blog posts recapping the experiences our associates had at the event.


lens-resized-462169457It’s a brand new year. A fresh start. A new year forces us to pause, puts things in perspective, and consider what we want for the future.

Have you vowed to make any changes? Perhaps you made a detailed plan for improving your personal life or advancing your career. Maybe your resolutions are broader and include things like exercise more and eat better.

Change pushes me to grow, enrich, and sometimes even transform. At this time of year, many of us commit to making a change, but individuals aren’t the only ones transforming.

According to a KPMG survey involving more than 900 senior executives from U.S.-based multinationals and asset managers, 93 percent of respondents surveyed indicated that they had just completed, are planning or are in the midst of a business transformation.

The statistic isn’t surprising when you consider today’s complex business environment. Shifts in the market, technological advances, disruptive innovations, and the regulatory landscape are just some of the triggers driving organizations to transform.

But transformations, whether at the individual or organizational level, take effort, time, and vision. Missing the mark in any one of these areas can easily derail your efforts. There’s been plenty of times when I’ve missed a step or two on my path of change. Tapping into expert guidance can be key to helping you succeed though.

I recently attended the Massachusetts Conference for Women, which featured a leadership track on transforming your organization and your life. Business leaders shared how they transformed their businesses and careers, lessons learned along the way, and the critical attributes needed to succeed.

I came away from the session with lots of practical advice, a lot of which I can use right away. And even if transformation isn’t part of your 2015 plans, change likely is. Here are a few ideas that might help you succeed.

Look at the lens framing your world:  We’re all subjective. This can cause us to overreact, judge people unfairly, or take something personally when it wasn’t meant that way according to Elizabeth Thornton, moderator for the session and author, speaker, and professor at Babson Executive Education. We need to be aware of our lens and consciously strive to increase our objectivity. Otherwise, how can we expect to transform ourselves, our organizations if we’re not aware of our underlying assumptions.

Possess a strong self-concept: What’s your mental picture of yourself? What is your belief system comprised of? How is it influencing the transformation? When driving transformation, we need to know when tapping into our attributes is a plus, when it’s a detriment, and adjust accordingly. For instance, if you’re leading a business transformation and you’re a perfectionist, you’re going to need to “let go” if you and your team are going to succeed.

See and accept things as they are: We don’t always see things the way they really are. No surprise, especially since we tend to frame the world with our subjective lens. But what is enlightening, is what happens when we increase our objectivity and don’t project our experiences and mental models onto things. We become better decision makers, relationships improve, opportunities open up, and yes, even transformation can occur.

Category: Conferences and Events

Our 2015 Events Calendar Announced!


event-calendarIt’s a New Year and we’re excited to share the Boston Financial and industry events we are planning for 2015. Break out those new calendars and mark the following dates. We hope you will join us as your time permits! Can’t attend an event? Throughout the year Boston Financial associates will be sharing takeaways right here on the Perspectives blog.

February 4: Investment Company Institute (ICI) Conference  – Will You Be Ready? Implementing the New Money Market Fund Rules. Marriott Wardman Park, Washington, DC. Boston Financial will attend.

February 8-10: 2015 NICSA Strategic Leadership Forum, Diplomat Resort, Hollywood, Florida.  Boston Financial joins DST and State Street as conference sponsors, exhibitors in the Resource Center, and hosts of a client dinner at the Diplomat Landing on Monday night. Boston Financial will moderate two thought-provoking panels of industry professionals:

  • Monday, February 9 at 11:00 AM, Anne Hebard, Managing Director at Boston Financial will moderate: “Put On Your Seatbelts, It’s Going To Be Quite A Ride!” with panelists Constance L. Hunter, Chief Economist, KPMG LLP; Mirtha Kastrapeli, Senior Research Analyst, State Street Corporation; and Daniel Egan, MSc, Director of Behavioral Finance and Investing at Betterment. This panel will discuss megatrends that will drive the investment management industry over the next decade.
  • Tuesday, February 10 at 2:45 PM, Kevin Caravella, Vice President of Blue Sky Administration at Boston Financial, will moderate: “Forecast: Clouds Making Way for Blue Sky”, with panelists Tamara Salmon, Senior Associate Counsel, Investment Company Institute (ICI); Janice Schwarz, Operations Project Manager, American Beacon; Tim O’Sullivan, Deloitte & Touche, and Mark Trenchard, Director of Operational Compliance, Putnam Investments.

February 23 – 25: DST’s ADVANCE Conference, Westin Kierland Resort, Scottsdale, AZ. The following Boston Financial attendees will participate in panel discussions alongside industry peers: Madeline FitzGerald, Managing Director Settlement Administration Solutions and Event Center; Craig Hollis, Chief Compliance Officer; Brian Melter, Managing Director E-Business Administration; and Mike Rizzo, Chief Information Officer.

March 15-18: ICI Mutual Funds & Investment Management Conference, JW Marriott Desert Springs, Palm Desert, CA. Boston Financial will join DST and State Street for a dinner hosted on Sunday night.  Location TBA.  Kevin Caravella, VP of Blue Sky Administration, will participate in a compliance panel discussion.

May 6-8: ICI General Membership Meeting, Marriott Wardman Park, Washington, DC. Boston Financial joins DST and State Street as conference sponsors. Please visit us in the Exhibit Hall at Booths 403-405. We will also be hosting a client dinner at the Top of the Hay Adams Hotel Wednesday, May 6.

June (date TBA): MFEA eCommerce Summit. Atlanta, GA. Boston Financial is a sponsor of the Summit and will attend.

June 11: Expect Miracles 21st Annual East Coast Classic, Boston, MA. Boston Financial is a sponsor and will attend.

September 20-22: Boston Financial 2015 Client Forum, The Peninsula Chicago, Chicago, IL.  Boston Financial returns to the windy city! Our program will begin Monday morning with your choice of Best Practice sessions, followed by an all-day general session. The Forum will end mid-morning Tuesday. More details regarding our agenda and evening events will be available come spring.

October 20: Boston Financial 2015 Chief Compliance Officer Forum, Mandarin Oriental Boston, MA. Our annual CCO Forum will begin with breakfast roundtable sessions followed by a full day of general sessions. That evening Boston Financial and State Street will cohost a networking reception. The State Street Chief Compliance Officer Forum will be held the following day on October 21.

October (date TBA): Expect Miracles 7th Annual West Coast Classic, Newport Coast, CA. Boston Financial is a sponsor.

October 29 – 30: NICSA General Membership Meeting, Boston, MA. Boston Financial will attend and sponsor.

November (date TBA): Expect Miracles 12th Annual Wine & Spirits Event, Boston, MA. Boston Financial is a sponsor and will attend.


Category: Associate Development and Engagement, Conferences and Events

33% of Your Time


DSC_0046As a leader, what is 33 percent of your time worth? The Creative Group published a study that cited 33 percent as a benchmark for the amount of time executives spend solving problems and fighting crises. In my words: looking backwards.

As you set your company and department resolutions for 2015, I want you to exclude four months of your available time for developing new business, increasing revenue, and adding value to your products because you will spend it solving problems and fighting crises – looking backwards. Last month I had the opportunity to speak with a group of leaders from Boston Financial at the company’s semi-annual manager’s meeting. As a former employee of Boston Financial, I was honored, flattered and excited to talk to this group at the height of their 2015 planning. I had a great experience during my time at Boston Financial, and now after a few decades of military service, I felt I was able to give back in a meaningful manner. Politics aside, many will agree there is no organization better at planning, executing and making decisions in fluid, dynamic, and often, violent situations than the Marine Corps and Special Operations Community. Because of this, I was able to offer Boston Financial leaders three military leadership methods to increase effective decision-making in the organization and gain back 33 percent of lost time in 2015.

First – Commander’s Intent. 


As the leader, you are responsible for defining the goals and objectives of your organization. If you want to operate at Steven Covey’s speed of trust, do not micro-manage your team. Tell them everything but the “how.” Build in a disciplined planning and intra-communication process to ensure you are kept abreast of the process and to ensure your goals are being met. Empower them, lead them, but stay out of their way.

Second – the LEADER planning process.  

After you deliver your “Commander’s Intent,” you want to ensure the plan and process your team develops will actually get you there. In the military, through a six-step planning process, we demand our subordinates offer three different solutions where each solution is feasible and unique, yet achieves the same result. By sourcing multiple solutions, the leader is no longer a problem solver but a decision-maker. Leaders maximize their personal time by leveraging their wisdom, experience, and judgment on well thought out, clear, concise, and distinct solutions, while not being part of the problem-solving team.

Through the issuance of “Commander’s Intent” and the implementation of a disciplined communication process, the leadership in your organization will gain back much of the cited 33 percent of lost time. Simultaneously, this approach will develop employees to think at a management level one to two levels higher than themselves. The power of having employees think and act in that manner is self-evident. But you can’t just direct innovation; it needs to be inspired from the top down.

Third – innovative cultures. 

You can’t innovate on Wednesday. Innovation has to be inspired and affirmed starting with the senior leadership and embraced at every level throughout the organization. Inspiring an innovative culture begins with recognition for the minor improvements and implementations that associates make on a regular basis. If associates know that their actions to improve the workplace and businesses processes are validated, it will inspire them to continually seek ways to give back and advance the organization. In order to increase loyalty, reduce sick leave, and improve morale, get out from behind your computers and smart-phones, walk around the organization, and thank people by name.

Do you want to increase organizational focus, speed of implementation, decision-making, execution, and employee loyalty? Do you want your organization to be innovative and transformational as it prepares for the challenges of the 21st Century? The implementation of these three techniques will certainly set you on the right path. My gift to you in 2015: 33 percent of your time back.

To read more about John’s talk at the Boston Financial Manager’s Meeting visit: When Crazy Ideas Move Forward