Global Firm Gutted Valuation Control Function

The SEC fined a large broker-dealer $5.75 Million for failing to allocate sufficient resources to its valuation control function, thereby allowing rogue traders to inflate securities valuations and positions.  The firm eliminated 15 valuation control positions as part of a global efficiency initiative, which, according to the SEC, left the control function understaffed and under-trained to adequately implement the firm’s valuation supervision policies.  One manager complained internally that four staff members were tasked with verifying prices for more than 20 trading desks that held over $200 Billion in Level 2 and 3 securities.  The SEC alleges violations of the books and records and supervision rules.

OUR TAKE: Having a valuation control function is not the same as having an effective valuation control function.  Global firms must consider metrics before gutting compliance and supervisory functions that could ultimately allow bad actors to put the firm at risk.  Firm leaders should think of compliance and supervision as the defense to protect assets and the firm’s reputation.  And, defense wins championships.