A. Personal Trading Monitoring Module (Module D must be provided in conjunction with Module A). A module which provides for personal trading monitoring and reconciliation of personal trading activities of certain employees, including personal trading preclearance and post-trade monitoring to detect potential violations of TRS’ Personal Trading Policy. The module must include the following features: 1. electronic broker feeds and pre-clearance of personal trades, as follows: a. electronic pre-clearance of personal trades that are automatically reconciled against rulebased restrictions, holding periods, and conflicts of interest; b. daily updates/refreshes, including personal trading activity and holdings; c. automated and instant notification of approval or denial of pre-clearance requests via email and the system; d. post-trade rules testing based upon surveillance of broker feeds; e. pre-clearance and tracking of private investment transactions; f. automated third-party broker feeds that provide statements at brokerage account level; g. broad library of client brokerage feeds (including, but not limited to, Charles Schwab, Fidelity Brokerage, Goldman Sachs, Interactive Brokers, Merrill Lynch, Raymond James, RBC Wealth Management, Vanguard, Wealthfront) which offers electronic connectivity between the brokerage, TRS’, and Contractor’s platform; h. status updates regarding broker feed success/failure, alerts for account reporting issues, and ability to reconcile transactions and holdings (either automatically or ad hoc); i. ability for users to upload supporting documentation and resubmit investment requests; j. case management for policy rule triggers and alerts, including workflows for addressing trade policy violations and other multi-tiered notifications (e.g., notices to supervisor, CCO review, closure of review)
