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Benchmarking Personal Investments / Employee Trading Programs

  • 1.  Benchmarking Personal Investments / Employee Trading Programs

    Posted 08-11-2022 02:39 PM

    Freddie Mac's Compliance & Ethics team is in the process of identifying potential enhancements to our trade monitoring program and its associated controls and would like to request input on what member companies (primarily in the financial and IT sectors) are doing in this space. Specifically, we'd like to inquire about processes you've implemented around the identification of employees and other personnel (contingent workers, contractors, board members, etc.) who are subject to trade monitoring, pre-clearance and related training, as well as the role their access to MNPI plays. A response is appreciated by Wednesday, August 31st

    Benchmarking Survey questions:

    1. What Industry/Sector is your company in?
    2. Do you require pre-clearance and/or monitor the personal trading activity of your employees?
    3. How do you determine which employees to include for pre-clearance and for monitoring? Do you identify employees by roles, responsibilities, and/or business processes in which the employee is involved that have access to Material Nonpublic Information (MNPI)?
    4. How frequently do you reevaluate/recalibrate the monitored list?
    5. Do you have any established processes to support consistent tracking and management of monitored employees if/when their roles change internally?
    6. Do your first line divisions/departments have supporting processes and/or controls in place to support the identification of monitored employees in their divisions/departments?
    7. Are any contingent workers (e.g. staff augmentation contractors, independent contractors, interns, etc.) subject to pre-clearance and/or monitoring?
    8. How do you define "contingent workers" for this purpose?
    9. Are there different criteria for monitoring contingent workers versus monitored employees (e.g. similarly situated)? How do you decide who gets monitored?
    10. Do you provide any reporting to your company's Board on the status (including KRIs and/or KPIs) of the insider trading, monitoring and personal investment program? If so, how frequently and what type of metrics do you share (e.g., repeat violations, intentional violation).
    11. Regarding personal trading activities, do you maintain a prohibited/restricted securities list? If so, have you established criteria to compile the list or do you restrict trading involving any third-party entity that has a business relationship with your company?
    12. How frequently do you reevaluate/recalibrate the prohibited/restricted securities list?
    13. If needed, could we/Freddie Mac follow-up with you directly (and briefly) to clarify your responses?
    14. Once the survey results have been consolidated, would you like to receive a summary of the results? 

    We'd also like to follow-up directly (and briefly-- five minutes, tops!) with any respondents to make sure that we are comparing apples and apples. Thank you in advance for your time and collaboration!


    April Johnson
    Compliance & Ethics Sr Manager
    Freddie Mac

    April Johnson
    Compliance Sr Manager
    Freddie Mac
    SCCE Membership