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Personal trading and preclearance software

Preclearance that applies your rules before a person has to.

A request comes in and Luna checks it against your restricted list, your short-term trading blackout and the household accounts subject to the same rules. Clear cases resolve themselves. Everything else arrives at your desk with the reasoning shown.

Included in Firm and Firm Plus

Luna's pre-clearance review queue: two requests pending review, an exchange-traded fund approved automatically, and a purchase in a fictional issuer by someone on its insider list denied automatically.

A screenshot of the product, with a demonstration firm’s data.

Advisers Act Rule 204A-1(c)

Access persons must obtain approval before acquiring beneficial ownership in an initial public offering or a limited offering. Most firms go further and preclear all personal securities transactions, which turns a rule with two named cases into a daily operational workload.

What it does

Restricted list screening

A request naming a security on your restricted list is denied automatically, and the employee is told it is restricted without being told what else is on the list.

Short-term trading blackout

Luna looks back over the window your policy sets for the same security, by the same person, and opens a human review when it finds one. It does not auto-deny, because the exceptions are real.

Household members included

Accounts of household members are subject to the same rules, and Luna applies them to those accounts too rather than treating the access person in isolation.

The reasoning is shown

Every rule that fired is listed in order for the reviewer, with the outcome. The employee sees a decision; the reviewer sees why.

Holdings and transaction reports

Initial and annual holdings reports, and quarterly transaction reports, as records with dates attached rather than a folder of attachments.

Brokerage accounts, linked

Employees link their brokerage accounts with their consent, and holdings and trades arrive on their own. Each new trade is checked daily against the restricted list, the approval it should have had (its window, side and size) and the short-term blackout. What it finds goes to compliance to decide.

Statements and confirmations, reviewed

For accounts that are not linked, employees upload their statements and trade confirmations, and compliance marks each one reviewed. The list shows whether each arrived within 30 days of quarter end.

Which rules fired, kept

The list of rules that fired on each request is stored, which is the evidence trail for an exam and the data for spotting which rule generates all your review load.

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