The Tech Toolkit for T+1 Compliance: Beyond the Basics

The transition to a T+1 settlement cycle is a monumental task for the financial industry, presenting not just operational challenges but significant regulatory implications as well. Prime Brokers, along with other entities, must navigate these waters with precision, leveraging technology not only to enhance efficiency but also to ensure strict regulatory compliance. Here, we delve deeper into the specific technological and regulatory requirements across different market participants, highlighting the importance of addressing Prime Broker processes, regulatory filings, and the consequences of non-compliance.

Prime Brokerage and Regulatory Compliance:

Prime brokerages can harness cutting-edge technology to navigate the intricate maze of regulatory compliance, ensuring seamless adaptation to the T+1 settlement cycle with unmatched precision and efficiency.

• Form-1 Schedule A’s, Form-150’s, and Form-151’s Management Systems: Prime Brokers are required to meticulously manage and submit these forms, critical for demonstrating compliance with various regulations. Advanced document management systems can automate the generation, storage, and submission of these forms, reducing the risk of errors and non-compliance.
• Quarterly Broker Files Processing Tools: To adhere to regulatory requirements, brokers must submit accurate quarterly reports. Tools that automate the compilation and submission of these files can prevent potential discrepancies and ensure timely submissions, crucial under the T+1 regime.
• DVP Trade and Letter of Freefund Processing Solutions: Delivery versus Payment (DVP) trades and the processing of Letters of Free Funds are integral to the Prime Brokerage function. Efficient systems to manage these processes are essential to comply with Regulation T and to ensure the smooth operation of credit extensions and settlements.
• Integrated Trading and Settlement Platforms: Beyond document management, firms require robust trading platforms that seamlessly integrate with T+1 settlement processes. These platforms should offer real-time transaction monitoring and support for Delivery Versus Payment (DVP) mechanisms to facilitate swift settlement.
• Compliance Automation Software: With the myriad of regulations governing financial transactions, including Reg-T and SEC rules, automated compliance solutions become indispensable. These tools continuously monitor for compliance, generate alerts for potential violations, and assist in preparing reports for regulatory bodies.
• Risk Management and Analytics: To navigate the shortened settlement cycle without increasing operational risk, firms must employ advanced risk management tools. These systems analyze large volumes of transactions in real-time, identifying potential settlement failures or liquidity issues before they escalate.
• Cybersecurity Solutions: The shift to digital and the increased pace of transactions elevate the importance of cybersecurity. Solutions that protect sensitive financial data from breaches and cyber threats are crucial, especially when handling increased volumes of electronic documents and communications.
• Cloud-Based Infrastructure: Embracing cloud technology allows firms to scale their operations flexibly and efficiently. Cloud-based storage and computing resources support the high-speed processing required for T+1 settlements, providing the agility to adapt to market demands.
• Data Archiving and Retrieval Systems: Effective management of historical trade data is essential for compliance, audits, and operational analysis. Firms need systems that can securely store vast amounts of data and facilitate quick retrieval for regulatory inquiries or internal reviews.

The Technological Blueprint for Compliance and Efficiency:

To mitigate these risks and capitalize on the move to T+1, firms should prioritize the following technological investments:

• Automated Compliance and Reporting Systems: Tools that automate the generation, submission, and archiving of regulatory documents and ensure compliance with updated SEC and FINRA rules.
• Real-Time Monitoring and Risk Management Platforms: Systems capable of providing real-time insights into trade statuses, potential settlement failures, and compliance risks are invaluable for navigating the T+1 landscape.
• Enhanced Communication and Data Exchange Solutions: With the tightened settlement cycle, ensuring efficient communication between counterparties, clients, and regulators is crucial. Investing in secure, real-time data exchange platforms can facilitate this need.

For Executing Brokers:

From brokers to hedge funds, the right technological infrastructure is key to mitigating risks, avoiding regulatory fines, and ensuring market stability. Here’s a breakdown of the tool types needed across various entities, along with the potential issues of inadequate preparation.

• Real-Time Transaction Monitoring Systems: These tools are essential for tracking trades as they occur, ensuring timely settlement within the T+1 timeframe. Without such systems, brokers face increased risk of settlement failures, potentially leading to regulatory penalties and eroding investor trust.
• Automated Compliance Platforms: To adhere to the accelerated settlement cycle, brokers need platforms that can automatically check for compliance with T+1 regulations, flagging potential issues in real-time. The absence of these tools could result in missed compliance issues, attracting regulatory scrutiny and fines.
• Enhanced Communication Tools: Efficient communication between brokers, clients, and counterparties is vital. Tools that facilitate swift and secure information exchange can help prevent misunderstandings and delays that compromise settlement processes.

For Clearing Brokers:

• Advanced Reconciliation Software: Clearing brokers require sophisticated software to reconcile trades accurately and quickly across multiple parties. Inadequate reconciliation tools can lead to errors and discrepancies, delaying settlements and affecting liquidity.
• Liquidity Management Solutions: Effective tools for managing liquidity are critical to ensure that funds are available for settlement. Without them, clearing brokers may struggle to meet their obligations, impacting their operational integrity and financial stability.

For Registered Investment Advisors (RIAs):

• Portfolio Management Systems: RIAs need robust systems to manage client portfolios efficiently, ensuring trades are executed in alignment with the T+1 cycle. Outdated systems could hinder timely trade execution, adversely affecting portfolio performance.
• Client Reporting Tools: With the faster settlement cycle, RIAs must provide timely updates to clients. Tools that automate and streamline reporting can help maintain transparency and client satisfaction.

For Hedge Funds:

• High-Frequency Trading (HFT) Algorithms: Hedge funds engaging in HFT will require algorithms optimized for the T+1 environment, ensuring strategies remain viable under the shortened settlement cycle. Ineffective algorithms could result in missed opportunities and strategy misalignment.
• Risk Management Software: To navigate the T+1 transition successfully, hedge funds need advanced risk management tools capable of analyzing and mitigating the increased operational and market risks associated with faster settlements.

Regulatory Needs and SEC Rules:

Entities must navigate a myriad of regulations, including Regulation T (Reg-T) of the Federal Reserve, which governs the extension of credit by brokers to clients for the purchase of securities. Adherence to SEC rules and FINRA guidelines is paramount, with technology playing a pivotal role in maintaining compliance and avoiding regulatory pitfalls.

• Regulatory Fines and Penalties: Failing to meet T+1 settlement obligations can attract significant regulatory fines, damaging a firm’s reputation and financial standing.
• Market Issues and Failures to Settle: Inadequate tools can lead to settlement failures, causing liquidity issues, eroding investor confidence, and potentially destabilizing markets.
• Operational Disruptions: Without the right technology, firms may experience operational bottlenecks, affecting their ability to compete and succeed in a T+1 landscape.
• Restrictions or Bars from FINRA: Repeated violations or severe non-compliance issues could lead to restrictions or firms being barred from FINRA, severely impacting their ability to operate within the financial markets.

Conclusion:

The leap to a T+1 settlement cycle necessitates a holistic approach to technological upgrades and regulatory compliance, particularly for Prime Brokers and other market participants heavily impacted by specific SEC and FINRA regulations. By embracing advanced technological tools tailored to the unique demands of the financial industry, firms can not only avoid the pitfalls of non-compliance but also enhance operational efficiency and market stability in the T+1 era. The stakes are high, and the time to act is now; the right technological foundation is not just an operational necessity but a strategic advantage in the swiftly evolving financial landscape.

Green Trades: How T+1 Settlement Reduces the Financial Industry’s Carbon Footprint

The shift toward a T+1 (Trade Date plus One Day) settlement cycle marks not just a significant transformation in the efficiency and risk management of financial transactions but also heralds an unexpected environmental boon. As the financial industry edges closer to this new standard, the potential for reducing the carbon footprint of trading activities becomes increasingly palpable. This blog post delves into the multifaceted environmental impacts of the T+1 settlement cycle, evaluating the contributions of both the Securities and Exchange Commission (SEC) and individual brokerage firms toward a greener trading environment.

Streamlining Operations: A Leaner, Greener Approach

The move to T+1 inherently demands a leaner approach to trade settlements. This streamlining of operations translates to reduced energy consumption across data centers and office operations, as the need for extensive manual processing diminishes. Moreover, with transactions being settled more swiftly, the overall energy expenditure associated with maintaining and running these systems is likely to decrease, contributing to a lower carbon footprint.

Digital Over Paper: The Eco-Friendly Shift

A significant environmental impact of the T+1 settlement cycle is the accelerated adoption of digital documentation over traditional paper-based methods. This transition not only aligns with broader trends toward digitalization but also significantly reduces paper waste, the demand for physical storage, and the associated logistics, such as transportation and delivery of documents, all of which contribute to carbon emissions. Brokerage firms, in adopting electronic communication and documentation, play a direct role in this reduction, contributing to sustainability goals.

The Role of the SEC in Environmental Stewardship

The SEC’s advocacy and regulatory framework for the T+1 settlement cycle inadvertently position the agency as a catalyst for environmental change within the financial sector. By endorsing and facilitating a move that reduces operational inefficiencies and promotes digitalization, the SEC can claim a share of the credit for the environmental benefits that accrue. The transition to T+1, therefore, is not just a regulatory shift but a policy move with significant green credentials.

Brokers as Environmental Champions

Brokerage firms stand to gain considerable environmental credit from the transition to T+1. By reengineering their systems and processes towards more energy-efficient operations and embracing digital over paper, brokers are at the forefront of this eco-friendly shift. Their role in educating and transitioning investors towards digital receipt of documents further amplifies their contribution to reducing the industry’s carbon footprint.

Quantifying the Environmental Impact: The Math Behind the Savings

Quantifying the exact carbon footprint reduction resulting from the move to T+1 involves considering several factors, including the decrease in paper usage, energy savings from streamlined operations, and the reduced need for physical logistics. While specific metrics may vary across firms, the collective impact across the industry could be substantial. Brokerage firms, in collaboration with environmental consultants, can measure and report these savings, leveraging them not just for regulatory compliance but as part of their corporate social responsibility (CSR) initiatives.

The T+1 settlement cycle is a stepping stone toward a more sustainable and environmentally friendly trading ecosystem. As technology continues to evolve, future settlement cycles could see even greater efficiencies and environmental benefits. The SEC, alongside brokerage firms, has the opportunity to continue leading the charge toward not only a more efficient but also a greener financial industry.

Conclusion

The transition to a T+1 settlement cycle represents a win-win for both the financial industry and the environment. Beyond the immediate benefits of reduced operational risk and increased market efficiency, the move stands as a testament to how regulatory shifts can yield significant environmental benefits. Both the SEC and brokerage firms play pivotal roles in this transition, underscoring the interconnectedness of financial regulation, market operations, and environmental stewardship. As the industry moves forward, the T+1 settlement cycle will likely be remembered not just for how it changed trading, but for how it contributed to a more sustainable world.

The Future of Finance: Insights from SEC and FINRA’s 2023 Enforcement Actions

Introduction

The Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) have long stood as the twin pillars of financial market regulation in the United States, ensuring that the complex and ever-evolving securities industry operates with integrity, transparency, and in the best interest of investors. As we dissect the enforcement actions and priorities revealed by both bodies for fiscal year 2023, it becomes evident that the landscape of compliance is not only vast but also intricately detailed, requiring a nuanced understanding of both the letter and the spirit of the law. This deep dive aims to unravel the patterns, highlight the emerging threats, and forecast the compliance focus areas for the near future, particularly in light of the imminent shift to a T+1 settlement cycle.

SEC’s 2023 Enforcement Actions: A Closer Look

In fiscal year 2023, the SEC filed 784 enforcement actions, marking a modest increase from the previous year, and obtained orders for nearly $5 billion in financial remedies. This effort underscores a robust approach to tackling a wide array of violations across the securities industry, from traditional billion-dollar frauds to emerging threats involving crypto assets and cybersecurity.

Key Patterns and Focus Areas

Record-Setting Whistleblower Awards and Tips

The SEC’s Whistleblower Program hit a new stride in 2023, awarding nearly $600 million to whistleblowers, including a record-breaking $279 million to a single whistleblower. This surge in whistleblower tips, which saw a 50% increase from the previous year, is a clear indicator of the SEC’s reliance on insider information to identify and prosecute violations. It underscores the critical role that whistleblowers play in the regulatory ecosystem, acting as the eyes and ears on the ground.

Crypto Assets and Cybersecurity

The SEC’s enforcement actions against crypto asset securities represent a concerted effort to address the burgeoning risks and regulatory challenges posed by this relatively new asset class. From billion-dollar fraud schemes to unregistered offerings and exchanges, the SEC’s aggressive posture reflects its intent to bring the crypto market within the fold of traditional securities regulation, ensuring investor protection and market integrity.

Gatekeepers Under the Microscope

Gatekeepers, including auditors, accountants, and brokers, faced significant scrutiny, with numerous actions aimed at ensuring they uphold their responsibilities. This focus highlights the SEC’s strategy to leverage the critical role gatekeepers play in preventing misconduct and ensuring accurate reporting and compliance across the board.

FINRA’s 2023 Enforcement Landscape

FINRA’s enforcement actions in 2023 continued to emphasize the importance of supervisory systems, recordkeeping, and the integrity of market operations. Notably, the actions spanned a range of issues from ensuring the integrity of electronic communications to addressing the adequacies of anti-money laundering programs.

Compliance and Supervisory Failures

A recurrent theme in FINRA’s enforcement actions is the failure of firms to establish and enforce adequate supervisory and compliance systems. This includes ensuring compliance with existing regulations, proper recordkeeping, and overseeing the activities of their representatives and clients.

In the complex and fast-paced world of financial markets, the role of compliance and supervision cannot be overstated. Both serve as the foundation upon which the integrity and trust of the financial system are built. As highlighted by the Financial Industry Regulatory Authority (FINRA) in its 2023 enforcement actions, there’s a critical need for firms to bolster their compliance and supervisory mechanisms. This segment explores the ramifications of compliance and supervisory failures, using insights from recent enforcement actions as a guide to understanding the landscape and pointing towards a path for firms to ensure robust compliance and supervision.

The Crux of the Matter

At the heart of many of FINRA’s enforcement actions in 2023 were failures in compliance and supervisory systems within firms. These shortcomings ranged from inadequate oversight of electronic communications to lapses in implementing effective anti-money laundering (AML) programs. Such deficiencies not only expose firms to regulatory penalties but also erode investor trust and can lead to significant financial and reputational damage.

Understanding the Failures

1. 1. Inadequate Oversight of Electronic Communications: With the digitalization of financial services, the management of electronic communications has become a focal point for compliance. Firms were found lacking in monitoring emails, social media interactions, and other digital communications effectively. This oversight is crucial not only for preventing the leakage of sensitive information but also for ensuring that communications with clients are compliant with regulatory standards.
   2. Lapses in Anti-Money Laundering Programs: AML programs are essential for detecting and preventing financial crimes. Failures in this area highlighted by FINRA include inadequate customer due diligence, failure to report suspicious activities, and not having a comprehensive AML compliance program in place. Such lapses not only contravene regulations but also expose firms and the wider financial system to exploitation by malicious actors.
   3. Deficient Risk Management Practices: Several enforcement actions underscored firms’ failures to implement risk management practices that align with their business model’s complexity and scale. This includes not having adequate controls to manage trading risks, credit risks, and operational risks effectively.
   4. Failure to Supervise: A recurring theme in FINRA’s enforcement actions was the failure of firms to supervise their representatives adequately. This includes not monitoring trading activities closely, failing to ensure that representatives are adequately trained and understand the products they are dealing with, and not having mechanisms in place to prevent unauthorized trading.

Pathways to Compliance

1. 1. Enhancing Technological Infrastructure: Leveraging technology to automate and streamline compliance processes can significantly reduce the risk of oversight. Tools that enable real-time monitoring of communications, automated alerts for suspicious activities, and comprehensive risk management solutions are essential investments for firms.
   2. Building a Culture of Compliance: Beyond technology and systems, fostering a culture of compliance within the organization is critical. This includes regular training for employees, clear communication of policies and expectations, and a top-down emphasis on the importance of compliance and ethical behavior.
   3. Regular Audits and Assessments: Conducting regular audits and assessments of compliance and supervisory systems can help identify potential weaknesses before they become problematic. These assessments should be thorough and cover all aspects of the firm’s operations, from trading practices to client communications and financial reporting.
   4. Engagement with Regulatory Developments: Staying abreast of regulatory changes and understanding their implications for the firm’s operations is crucial. This proactive approach to compliance can help firms adapt their policies and procedures in time to meet new regulatory requirements.

The Evolving Threat of Cybersecurity

Like the SEC, FINRA has placed a significant emphasis on cybersecurity, reflecting a broader industry trend towards digitalization and the associated risks. This includes ensuring that firms have adequate policies and procedures to protect sensitive customer information and to respond to cybersecurity threats effectively.

In recent years, the financial industry has witnessed an unprecedented increase in cybersecurity threats, ranging from data breaches and ransomware attacks to sophisticated phishing schemes. These incidents not only compromise sensitive client information but also pose systemic risks to the integrity of global financial markets. Reflecting this heightened risk landscape, both the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) have intensified their focus on cybersecurity compliance, leading to an uptick in fines and disciplinary actions against firms failing to safeguard against these evolving threats.

Cybersecurity in the Regulatory Spotlight

The SEC and FINRA have made it abundantly clear that cybersecurity is not merely an IT issue but a cornerstone of a firm’s overall compliance and governance framework. This paradigm shift is evident in the enforcement actions and fines levied in 2023, which underscore the regulators’ expectation that firms adopt robust, proactive measures to address cybersecurity risks.

1. Enhanced Regulatory Expectations: The regulatory bodies have outlined specific cybersecurity expectations, including the implementation of comprehensive risk assessments, the establishment of effective governance structures, and the deployment of adequate incident response and recovery plans. These expectations have been reinforced through guidance, risk alerts, and, increasingly, through enforcement actions against firms demonstrating lapses in their cybersecurity defenses.
2. Notable Enforcement Actions and Fines: In 2023, several high-profile enforcement actions highlighted the consequences of cybersecurity failures. For instance, cases involving inadequate protection of customer information, failure to disclose cybersecurity breaches in a timely manner, and insufficient controls to prevent unauthorized access to sensitive data led to significant fines. These actions signal regulators’ willingness to impose stiff penalties for non-compliance, underscoring the importance of cybersecurity in the broader regulatory compliance agenda.
3. Cybersecurity as a Component of Overall Compliance: Beyond specific cybersecurity practices, enforcement actions have also emphasized the integration of cybersecurity considerations into the overall compliance framework. This includes the need for ongoing employee training, the integration of cybersecurity risk into the firm’s risk management processes, and the importance of board and senior management oversight in cybersecurity matters.

The Impact of Cybersecurity on Fines and Disciplinary Actions

The impact of cybersecurity on regulatory fines and disciplinary actions is multifaceted, reflecting the complexity and evolving nature of cyber threats. Several key themes have emerged:

1. 1. Quantum of Fines: The quantum of fines related to cybersecurity lapses has seen a noticeable increase, reflecting the severity with which regulators view these infractions. This trend is expected to continue as the financial and reputational implications of cyber incidents become more pronounced.
   2. Basis for Disciplinary Actions: Disciplinary actions have been based on a variety of failures, including the lack of comprehensive cybersecurity policies, failure to implement recommended security measures, and inadequate response mechanisms to detected breaches. These actions highlight the comprehensive approach regulators are taking towards cybersecurity, examining every facet of a firm’s cybersecurity posture.
   3. Focus on Preventative Measures: A significant portion of the fines and disciplinary actions has been directed towards firms’ failures to implement preventative measures. This includes deficiencies in encryption, firewall configurations, and the monitoring of systems for unauthorized access. The emphasis on prevention underscores the expectation that firms take a proactive stance in safeguarding against cyber threats.
   4. Cybersecurity Disclosures: Regulators have also focused on firms’ obligations to disclose cybersecurity risks and incidents to investors. Enforcement actions have targeted firms that either failed to disclose such incidents in a timely manner or downplayed the severity of breaches, misleading investors and the market at large.

One Notable Example of a Cybersecurity related fine 

Moving Forward: Strengthening Cybersecurity Compliance

The evolving threat of cybersecurity necessitates a dynamic and forward-looking approach to compliance. Firms are encouraged to adopt a culture of cybersecurity resilience, emphasizing not just technical defenses but also governance, employee training, and incident response readiness. Engaging in regular audits, staying abreast of the latest cyber threats, and fostering a collaborative relationship with regulators are key steps in mitigating the risk of fines and disciplinary actions related to cybersecurity.

The Impending T+1 Settlement Cycle: Implications for Compliance

The transition to a T+1 settlement cycle, set to occur within the next 84 days for the US and 83 days for Canada, represents a significant operational shift for the securities industry. This change aims to reduce credit and market risks, enhance operational efficiencies, and align the U.S. markets with other global markets that have already moved to shorter settlement cycles.

Historical Context and Regulatory Precedent

Historically, regulatory bodies like the SEC and FINRA have not hesitated to impose fines and disciplinary actions for failures in systems and controls that compromise market integrity, investor protection, or fair trading practices. With the implementation of T+1, these regulatory entities are likely to closely monitor firms’ adaptation to the new settlement cycle, focusing on areas such as risk management, operational resilience, and compliance with settlement and clearing obligations.

Potential Areas of Regulatory Focus

1. 1. Operational Readiness and System Failures: Firms must ensure their systems are robust enough to handle the increased speed of settlement under T+1. Failures that lead to delays or inaccuracies in trade settlement could attract regulatory scrutiny and potential fines, as these would directly contravene the objectives of the T+1 initiative.
   2. Risk Management Practices: The shorter settlement cycle will necessitate tighter risk management controls to manage the accelerated flow of funds and securities. Firms that fail to adjust their risk management frameworks to account for the reduced window for identifying and addressing settlement risks might face disciplinary actions for inadequate risk controls.
   3. Disclosure and Communication to Clients: Regulators will expect firms to effectively communicate the implications of T+1 to their clients, ensuring investors are aware of the changes to trade settlement times and how these may affect their trading activities. Inadequate client communication may be viewed as a failure to uphold high standards of investor protection.
   4. Recordkeeping and Reporting: The shift to T+1 will also impact recordkeeping and reporting requirements. Firms will need to ensure that their systems are capable of accurately tracking and reporting transactions within the compressed timeline. Non-compliance in this area, given its importance to market transparency and regulatory oversight, could lead to significant penalties.

Anticipated Disciplinary Actions and Fines

Drawing on the regulatory focus areas outlined above, we can anticipate that firms may face fines and disciplinary actions if they:

• • Experience systemic failures that lead to delayed or inaccurate trade settlements, potentially undermining the efficiency gains intended by the shift to T+1.
  • Fail to demonstrate that they have adequately adjusted their risk management frameworks to address the unique challenges and risks presented by the faster settlement cycle.
  • Do not provide sufficient information and support to clients regarding the transition to T+1, leading to potential investor harm or confusion.
  • Exhibit lapses in recordkeeping and reporting, compromising the ability of regulators to maintain oversight of market activities and ensure compliance with securities laws.

Compliance Challenges and Opportunities

The shift to T+1 will require firms to streamline their operations, enhance their technological infrastructure, and revise their compliance and risk management frameworks to adapt to the faster settlement timeline. This includes ensuring accurate and timely trade reporting, enhancing liquidity management practices, and ensuring robust communication with clients regarding the implications of the shorter settlement cycle.

Looking Ahead: Compliance in a Rapidly Evolving Landscape

As we look to the future, it is clear that the SEC and FINRA will continue to adapt their enforcement strategies to address the evolving risks and challenges of the securities industry. The emphasis on whistleblower programs, crypto asset regulation, cybersecurity, and the integrity of gatekeepers signals a comprehensive approach to ensuring market integrity and investor protection.

The Road Ahead

The transition to T+1 presents both challenges and opportunities for market participants. Firms must proactively engage with the changing regulatory landscape, leveraging technology and innovation to meet compliance requirements efficiently and effectively. Additionally, the continued growth and integration of digital assets into the financial ecosystem will likely remain a focal point for regulatory bodies, necessitating a forward-looking approach to regulation and compliance.

Final Thoughts

The enforcement actions and priorities outlined by the SEC and FINRA in 2023 serve as a roadmap for firms navigating the complex regulatory environment of the securities industry. By understanding these patterns and preparing for the changes ahead, firms can not only ensure compliance but also contribute to a more stable, transparent, and investor-friendly market. As the industry continues to evolve, the role of regulation in shaping the future of finance remains undiminished, with the ultimate goal of fostering trust, integrity, and innovation in the markets.

Loffa has been helping firms for over 20 years, the CEO has extensive experience working with Prime Broker agreements, DVP trade verification, and SEC 17a-13(b)(3) and storing SEC 17-(a)-4 letters for 20+ years.  Our Operations team is extensively trained and can assist in you your workflow processes.  Give us a call today:  Tel: 480 405-9662