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Wall crossing
Bring people over the wall from one request, restrict their trading, and keep a dated record the examiner can read.
Trusted by the world's leading companies
Requested by the deal team. Approved by you.
Exchange Act 15(g) and Advisers Act 204A require written information-barrier procedures, and examiners ask for the audit trail.
Take requests from the deal team
Your deal team names the client, the people, the reason, and the securities, then submits from the portal. Nothing is created until compliance decides.
Learn more about user portals
Approve to open a matter
Compliance approves or rejects with comments. On approval the MNPI matter opens, each person named is notified, and signed acknowledgments come back by emailed link.
Learn more about MNPI matters
Restrict the people you cross
Each affected security joins your restricted securities for the people crossed. Their pre-clearance requests for it carry a flag only the reviewer sees.
Learn more about restricted securitiesFrom request to cleansing in three steps.
Request
Your deal team submits the client matter with the people, the reason, and the affected securities, so compliance sees everything needed to decide.
Approve
Approval opens the matter, sends the notices, and restricts the securities for those people. Rejection returns the comments and creates nothing.
Cleanse
Close the matter on announcement, or remove a person when their part ends, to end the restriction and record the date.
In depth
Record every step of the crossing.
Your deal team requests, compliance decides, and each person signs.
Name the client, people, and securities
Your deal team picks the client and names the people in sales, trading, or research by email address. They state the reason and select the securities by ticker or identifier.
Compliance opens the request with the five fields examiners expect (employee, department, date, issuer, and requester) already on it.
Approve or reject with comments that reach the requester either way. Each decision is recorded with who submitted, who decided, and when.
Send each person crossed a notice to sign.
On approval the MNPI matter opens for the client, with each person crossed as a recipient and the time they obtained access.
Each person receives your MNPI memorandum and an emailed link, confirms their details, accepts the statements, and signs on any device.
Everything on MNPI matters applies, so outstanding names stay on the matter and reminders run in your wording.
Restrict each affected security.
On approval, each affected security joins your restricted securities for its recipients, beside firm-wide restrictions for mandates, board seats, and your own stock.
A pre-clearance request from any of them for that security reaches the Trade pre-clearance desk with a flag naming the matter.
You weigh it in your decision, and it never reaches the requester, as Restricted securities explains.
Record the date of every cleansing.
Close the matter when the information is public, or remove one person when their part ends, to cleanse them.
Close the matter to end every restriction it created, or remove one person to end theirs alone. Each end date is recorded automatically.
Recipients receive the closure notice, reminders stop, and nothing is deleted, so the restriction history exports with the matter.
Worked example
Follow a client matter from start to finish.
A law firm's partner brings three people across for a client's acquisition.
Request
A partner opens a "Bring over the wall" request naming two associates and a research analyst, with the client's ticker as the affected security.
Restriction
Compliance approves, the three sign, and the ticker is restricted for them. A week later the analyst's request to buy is flagged and rejected.
Cleansing
On announcement the partner closes the matter, and the restriction ends with its date. A year on, the examiner reads that client's wall-crossing record in date order.
Evidence
Exports an examiner reads without a walkthrough.
Each export is scoped to one client, dated, and in date order.
Export each client's history
See every crossing for a client in date order, from request to cleansing.
Trace every restriction
See who was restricted in which security, from when until when, and on whose approval, beside the standing restrictions.
Show who had access
See who had access and what they signed in one file per client or per matter.
Set your own retention period
Keep records for the period you set, with the Advisers Act, Exchange Act, and FINRA books-and-records floors shown beside that setting.
Syndicate desks and placement agents run wall-cross soundings for the same client. Read more on Financial & legal firms.
What compliance teams say.
See how listed companies, advisers and funds run their insider trading programs with InsiderList.
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Company Secretarial Assistant
Computacenter plc
With InsiderList, we can quickly create lists, track acknowledgments, and effectively manage the deal clearance process. This has saved time and reduced the administrative workload. The platform is easy to use and the support has been great.
Christa Zillwood-Hunt
General Counsel
LendInvest plc
After conducting a thorough review, InsiderList stood out as the clear market leader. Their advanced technology platform, deep understanding of the regulatory landscape, and ability to integrate into our core products sets them apart.
Thera Prins
CEO
Equiniti Shareholder Services (UK)
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