In the first article of this series we provided a core definition of what the “Amazon retail experience” is, and what the fundamental challenges are for an Investment Manager to solve in order to enable it.
We have elaborated previously on the product definition data model of the logical solution architecture, the implementation of a channel agnostic distribution model and the high level of automation the logical solution architecture enables. So, we will cover the relevance of these to the current topic in the concluding article in this series.
Here, we will elaborate on the systemic compliance model. In particular, what the “business rules” mechanism enables and, thus, how the logical solution architecture enables Investment Managers to implement systemic compliance, the mission critical component of the “Amazon retail experience”.
First, let us return to a key definition in the previous white paper, The Digital Transformation of Asset Management: Challenges and Solutions: the definition of content.
Content is not just another word for data and information, it is a more sophisticated concept:
Content = data + context
Context prescribes how data and information is to be presented. For example, if, when and how it is to be presented in individual documents, individual channels and individual jurisdictions.
In simple terms:
Data is the what of communications
Context is the when, where, and how
Defining, and maintaining, a difference between data and context, at the component level, and implementing a means to dynamically combine them into content, is a prerequisite of enabling the deep personalisation required to enable the “Amazon retail experience” model for Investment Managers.
Without such a logical separation, and a means to dynamically combine them into content, it becomes impossible to:
Business rules are the primary means which enable this deep personalisation within the logical solution architecture: the responsive distribution of product information, as defined by the context of its consumption.
Business rules define and control three fundamental aspects of personalisation in product distribution. Firstly, what data is to be included, secondly, what is the context to be applied and, thirdly, how is this to be presented.
A request for product information will trigger the aggregation of the relevant components of product data. This initial request also defines the distribution channel, such as a web fund centre, a mobile app, PDF or colour separated print, or any combination of these, ad infinitum.
A first business rule could, for example, narrow the aggregated data set it to a particular, or to a particular set, of available share classes, according to the context defined by this request.
Another business rule could then be applied to define and control the context of this narrowed data set. This context could be a particular jurisdiction. So, for example, the regulatory requirements of the Chinese market could be applied to the data selection - including the relevant disclosures and disclaimers and instruction to include the Chinese language fund commentary and other textual data components. Similarly, chart x-y axis definitions would also be in Chinese. As well as the localisation of dates, measurements and currencies within content.
Another business rule can then be applied to control and define the presentation layer of this data set. For example, in the current context, this fund may be marketed under a subsidiary brand and, unlike, say, the Italian market, the top ten holdings are to be presented in a table format rather than as an interactive pie chart.
Business rules are created and maintained within the change control and approval functions of the logical solution architecture. A compliance team can readily be integrated with the business rule definition process, as well as the checking and approval of the results of business rules. Together, this allows the systemic approval of distribution across all channels through a fully defined and robust business process.
Business rules provide a systematic means of enabling compliance in the distribution of product information across multiple regulatory environments and across multiple distribution channels. Compliance and legal teams sign off the business rules, rather than each and every output. Of course, spot checks are part of this defined business process, but far from the entirety of it.
And, of course, business rules can be applied to produce regulatory documents, such as the current KIIDs and future PRIIPS requirements, from the same operating model as the one supporting sophisticated digital enablement.
The concluding article in this series will revisit the definition and qualification of the challenges an Investment manager faces in enabling an Amazon retail experience and how the logical solution architecture addresses them.