MNPI register and restricted list
Who knows what, since when, and whether it is still non-public.
Record each piece of material non-public information as a matter, keep the insider list for it, and Luna refuses preclearance to anyone on that list in the securities it covers. Every day it checks each open matter for a review falling due, an expected announcement date passing, and new SEC filings by the issuer.
Included in Firm and Firm Plus
A screenshot of the product, with a demonstration firm’s data.
Every registered adviser must establish, maintain and enforce written policies and procedures reasonably designed to prevent the misuse of material non-public information by the firm or anyone associated with it. The record of who held what, and when, is how a firm shows those procedures were followed.
What it does
Each matter, recorded once
A code name, the issuer and its tickers, the kind of information (earnings, a deal, a financing, a board role, regulatory, a management change), where it came from, when it was received and when it is expected to become public. The code name is what appears in notices; the substance never goes into an email.
The insider list
People at the firm and people outside it, each with when and how they received the information (meeting, call, email, document or data room), why they need it, and who added them. Ending someone's access takes a reason, and the earlier entries stay on the record.
Preclearance refused for insiders
A person on the insider list of an open matter is denied preclearance in its securities automatically, household accounts included. The employee is told to speak with compliance, not why.
Restricted list, without naming the matter
Optionally put a matter's securities on the firm-wide restricted list. Everyone sees them as restricted by compliance and nothing more. Clearing the matter takes them off again.
A daily check of every open matter
Luna flags a review that has fallen due on the cadence you set, an expected announcement date that has passed, and any current report, periodic report, deal, tender or offering document the issuer has filed on SEC EDGAR since the information was received, finding the issuer by its ticker or the CIK you enter. It flags; it never clears a matter for you.
Trades by people on the list
The same daily check looks for any trade recorded in Luna in the matter's securities by someone on its insider list, during the time they were on it, and flags it for review.
Employees can report it themselves
An employee who thinks they have received MNPI reports it in Luna. It is recorded at once, their preclearance in those securities is blocked straight away, and compliance is notified to confirm it or clear it.
Cleared with a reason
Made public, no longer material, transaction abandoned, or reviewed and found not to be MNPI. Made public requires the evidence. Clearing ends everyone's access, lifts the restriction and tells the employees who were on the list.
Acknowledgement from each insider
Employees added to a list are emailed to say so and acknowledge it in Luna, where they see only the matters they are on, never the substance. Anyone who has not acknowledged after two days is flagged.
A log, and an export for the examiner
Every change is logged, including who opened a matter's details. The insider list and the log export to a spreadsheet for an examiner or outside counsel.