Monthly Archives: November 2016

Category: Compliance, Money Market Reform

Money Market Reform: What’s Next?


The go-live-date for money market reform has come and gone. It was a seemingly non-event. Yet for the industry, October 14 marked the culmination of more than two years of extraordinary effort and collaboration. ICI President and CEO Paul Schott Stevens aptly described the industry’s approach to money market reform as, “substantial effort, planning, and execution within the industry…”

At Boston Financial and DST, we logged over 150,000 hours from a development and implementation perspective. Countless hours were also spent consulting with clients, participating in industry working groups, and collaborating with clients during money market town halls, webcasts, and forums.

The industry should feel good about successfully meeting the myriad of challenges presented by the money market reform, starting with product line-up decisions and culminating with the transition of prime institutional funds to a floating NAV.

But just because the industry has successfully met the go-live-date doesn’t mean daily monitoring, planning, and preparation have stopped.Photo working process. Account manager work new global project in

The Landscape Today

Across the industry, retail fund policies and daily procedures are in place and being monitored, with minor adjustments being made as needed. Asset managers are performing final reviews of prospectus language for accuracy and clarity. Intermediaries and investors are settling into new strike schedule routines.

Clarity around expectations and detailed planning resulted in successful Columbus Day and Veteran’s Day bank holiday events. But there are still some ‘firsts’ to be managed, including market holidays, unexpected market closes, and unplanned fund or market events.

What to Focus on Now

Speaking of unplanned fund events, money market funds are now required to support fees and gates. The purpose of a fee is to mitigate the cost of high transaction volume to shareholders who remain in the funds during a volatile market/fund event. Gates block all redemptions from a fund. Fees and gates can apply to both Institutional and Retail money market funds.

A fund may never need to implement a fee or gate; however, both fees and gates present numerous communication and operational considerations. With the go-live-date successfully behind us, now is a great opportunity for funds to review their fee/gate implementation strategy. picture1

Fee/Gate Strategy

There are a number of factors that a fund needs to consider when evaluating their strategy. One of the biggest priorities is communication. Coordinated and effective communication is essential, and it starts with the fund’s transfer agent and intermediaries. They’re only the beginning though.

Funds should identify all the external parties they will need to communicate to and document the communication workflow for each party.

Questions You Should Be Asking  

To help with your planning, we’ve identified some high-level questions that funds should consider when developing and reviewing their plan.

When implementing a fee or a gate, what information will need to be provided to your transfer agent?

Here’s a guideline of some of the information a transfer agent may require:

Fund(s) Impacted:

  • The name(s) and number(s) of the fund(s) impacted

If a Fee is Being Imposed:

  • The fee rate
  • The effective start date and start time
  • The expiration date and time (if known)

If a Gate is Being Imposed:

  • Whether the fund will allow broker/dealers to bypass the gate
  • The effective start date and start time
  • The expiration date and time (if known)

Is the communication protocol the same for both normal business hours and non-business hours?

If the process is different, it is important to identify and document the workflow process for each scenario. Notifying your transfer agent of a potential fee/gate as early as possible is vital. It will help ensure that the appropriate resources have not only been allocated but are also ready to be deployed.

How long will it take your transfer agent to implement a fee/gate upon notification?

Funds should have a general understanding of how long it will take their transfer agent to implement a fee/ gate request. If a fund has any unique, client-specific tasks, they will want to make sure these tasks are accounted for in the projected time frame.

Additionally, an industry-wide event may impact the “standard” time frame that has been communicated by the transfer agent. A fund should know in advance if the time frame will change if an industry-wide event were to occur so they can plan accordingly.

Is a “Dry Run” Needed?

A dry run allows funds to put their plans into action. It provides funds with valuable perspective on how thorough their plan is, the opportunity to refine it, and ultimately increases confidence in the plan.

A dry run should involve individuals from all key business areas within the fund. As a fund’s board is part of the fee/gate implementation protocol, the fund should think about involving the board in the dry run. Funds may also want to consider including their strategic, external partners as well.

Our questions are not a definitive list of everything that a fund must consider, but should provide a guideline to the breadth of possible impact.

Keith Madden, Boston Financial’s lead spokesperson and subject matter expert on money market reform, also contributed to this post. Some background on Keith:


Keith Madden, Relationship Manager, Boston Financial


Keith, a relationship manager for Boston Financial, has more than two decades of experience in financial services, with expertise in retail, institutional, and 529 products. Keith joined Boston Financial in 1998 as a client service officer managing a multi-client operations team. During his tenure at Boston Financial, Keith has always played an integral role in Boston Financial’s relationship management program and continues to have an impact. Today, he manages one of Boston Financial’s key client relationships. Keith earned a Bachelor of Science in Business Administration from the University of Massachusetts, Lowell.


Category: Technology

2016 Gadget Guide


It’s that time of year again, the holiday shopping season. Each year the holiday shopping season seems to start earlier and earlier, but Black Friday and Cyber Monday still represent some of the biggest shopping days. And to help you this holiday season, I’m back with Boston Financial’s annual gadget guide. So whether you’ve already begun your shopping or plan to very soon, our annual gadget guide can help you find something for everyone on your list.



Ring Doorbell & Stick Up Camera ( $199


Replace that plain doorbell button with the Ring and you will not only be able to see video of what happens at your front door, but also speak to visitors and receive alerts when motion is detected — even when the doorbell has not been pressed. Footage and alerts come to you on your smartphone or tablet, and can be stored in the cloud for future viewing.

This gadget is useful to see delivered packages, who is at the door, and to have some fun with solicitors (and pets). And, the two wire hook-up makes it easy to replace your existing doorbell.

The Ring Stick Up Camera has the camera and motion sensing without the doorbell, allowing you to view and monitor other places inside or outside of your home.

Bonus feature: It’s the only gadget on the guide that received my wife Paula’s seal of approval versus her usual refrain of “Oh no, what’s this thing?” whenever a new gadget arrives at the house.



Yeti Colster ( $30


Who loves warm beer? That’s right, no one! Yeti has taken their cooler expertise and brings it to your can or longneck with the Colster. Keep your drink cold until the last sip. Shun those with the flimsy, non-insulating cozies, drinking their lukewarm beverages with a frown on their face.

And you thought we only loved electronic gadgets. Whether we are plugged in or unplugged, we have our Yeti close by.



Amazon Echo ( $179


A popular item from a prior list has taken the world by storm and many (including Google and Apple) are playing catch up. With the Echo, not only can you easily access news, weather, and other information using simple voice commands, but also control household items like lighting, alarm systems, music, and much, much more.

For example, “Alexa, open Domino’s” will get you to your pizza profile and allow you to order up your favorite pie without lifting a finger. With third parties rushing to integrate with this household helper, it’s the current market leader. Just remember, Alexa (the name of your Echo helper) is almost always listening.



Opal Nugget Ice Machine ( $449


For those who love, crave, or otherwise worship the small nugget ice chips you get from Sonic or the hospital with their cold, chewy goodness, you can now have that same experience at home with the Opal Nugget Ice Maker. Self-contained and no plumbing needed, it can produce up to one pound of pure cold delight per hour.



Google Daydream ( $79


Visit the Louvre, tour Venice, and walk the streets of Boston without leaving the comfort of your home with Google’s entry into the virtual reality space. Made of soft fabric in a variety of colors, simply slide in your Google Pixel phone (more phones to be supported soon) and be transported to foreign, alien, or other lands in an instant. The cheapest travel experience with no packing involved!



Samsung Gear S3 Frontier Watch ( $349


Dick Tracy has arrived with the latest (and IMO, the best) smart watch out there. No need to tether this watch to your phone, as it can make and receive calls on its own, “Give me a call on my watch.” It can also alert you with texts, news, weather, sports, and has a ton of specialty apps as well. Don’t like the look of the face today? Download a new one and change it based upon your mood, clothing, or event.

It’s a fitness tracker, smartphone, watch, and so much more, and it comes in a tidy and elegant package that can go for a couple of days without the need to recharge.



Nintendo NES ( $60


It’s back in its original form! Forget those newfangled systems that have controllers with 20 buttons and two joysticks. Go old school with the original Nintendo NES system, which has been reintroduced just in time for the holidays.

A full remake of the 1985 original Nintendo, the Nintendo NES sports an HDMI output and also connects to power via a micro USB port. So conceivably, you could use  a USB battery pack to power in when you’re on the go. Play Super Mario Bros., Donkey Kong, Zelda, Punch Out, and all of the classics! Pair it up with an old tube TV and you’ve gone full retro!

Good luck finding one for list price, as they have  already become the hot “must have” item.



Philips Hue ( Prices Vary



Add LED bulbs and light strips to your home in a different way. With Hue, not only can you control the lighting throughout your house, but depending on the bulbs you install, you can also change the color of the lighting, wake up to gradual lighting, sync lights with movies and music, and more.

Hue can also be integrated with many popular home automation systems such as, Apple HomeKit and SmartThings.



Flir One ( $249


Turn your smartphone or tablet into a true thermal camera similar to those used by first responders. Use it around the house to check for air leaks, hunting, boating, and other recreation. Give it to your kids and hide and seek will not be as much fun anymore. Attach the Flir One to the charging port of your smartphone or tablet, and you’ll be able to see through the darkness.




Category: CCO Forum, Compliance, Conferences and Events

CCO Forum: Looking Ahead


What are some of the issues that matter most to CCOs these days? DOL Fiduciary Rule, third-party oversight, and resource constraints would surely be on any CCO’s top 5 list. These topics, as well as others, were discussed at Boston Financial’s annual Chief Compliance Officer Due Diligence Forum.

If you are not familiar with our CCO Forum, it provides our clients’ CCOs the opportunity to get a closer look at some of the topics that matter most to them and their boards. Every year the Forum is a little different, with either a certain regulatory initiative driving the agenda or market trends driving a theme. This year’s Forum showed me that more than ever, Boston Financial is “walking the walk” when it comes to addressing everything from new regulatory requirements to disruptive industry business events.

More than ever, it appears that politics is influencing policy. The impression I received from the speakers at this year’s Forum was that the SEC’s rulemaking binge has a lot to do with the political environment in Washington, and the potential changes that could come in 2017.

The ominous FSOC (Financial Stability Oversight Council), the struggle with commissioners’ nominations, and an upcoming change of SEC leadership has caused increased pressure on the staff to finish off the Dodd-Frank related rulemaking, as well as Chair White’s own remaining policy objectives.

And let’s not forget about the paper lobby’s win over 30e-3, which grabbed the headlines leading up to the Forum. In addition to the win, the paper lobby must also be celebrating the heftiness of the rules, proposed and final, which are hundreds of pages long. Combined with the efforts of other agencies, namely the Department of Labor, it is no small feat for fund compliance officers to stay current with the implementation of all these regulatory requirements.

cco-forum-post_craigOne of the perennial fan favorites of this event is always the CCO panel, made up of fund CCOs and senior compliance officers. Moderated by our CCO, Craig Hollis, this year’s session did not disappoint. Representing large asset managers, each with a unique perspective, the panel covered a number of topics I know are on clients’ minds lately, including:

  • Resource constraints in an ever-expanding regulatory environment
  • DOL Fiduciary Rule preparations
  • Third-party oversight
  • Report Modernization – what the SEC is going to do with all this data they’re getting their hands on

With such a broad, far-reaching impact, the DOL Fiduciary Rule was brought up numerous times throughout the day (not surprisingly). While there are still more questions than answers related to how funds and firms will adapt to the rule, Boston Financial is clearly plugged in, keeping aware of developments, and ready to follow an implementation methodology grounded in client collaboration and subject matter expertise.

Another staple of the Forum is the business operations update from Boston Financial. This year Boston Financial approached the update in a different manner, bringing together representatives from our functional areas that have seen the most impact from regulatory change. The panel gave us a look into the frontlines of regulatory implementation at Boston Financial. While we are cautiously optimistic following the well-received implementation of money market reform, the industry has a lot to do to be ready for the changes in landscape the DOL Fiduciary Rule will dictate.

2017 looks to be another year that will bring unexpected change, as well as the expected increase in regulatory requirements. From this year’s Forum, the message I took away is that Boston Financial is better prepared to handle change than ever before. Straight open road to upcoming 2017 at idyllic sunset