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Paul G. Cellupica, Division of Investment Management Deputy Director and Chief Counsel to Conclude Tenure at SEC

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Washington, D.C.–(Newsfile Corp. – January 7, 2021) – The Securities and Exchange Commission today announced that Paul G. Cellupica, Deputy Director and Chief Counsel of the Division of Investment Management, will depart the agency later this month.

Mr. Cellupica rejoined the division as Deputy Director in November 2017, and became Chief Counsel in June 2018. The division’s Office of the Chief Counsel, among other responsibilities, is responsible for responding to requests for legal and policy guidance, evaluating applications for exemptive relief, overseeing the division’s liaison with the Divisions of Enforcement and Examinations, technical assistance on legislation affecting investment advisers and funds, and engagement with international regulators on matters related to asset management.

“Paul’s expertise, deep knowledge of the asset management industry and commitment to the SEC have been invaluable assets as we navigated through much needed regulatory reforms and the market disruptions caused by the COVID-19 pandemic,” said Dalia Blass, Director of the Division of Investment Management. “His dedication to the work of the Commission and the division will have a lasting impact for years to come, and I thank him for his counsel to me and his many years of public service to the Commission.”

“I have been fortunate to have worked with such a talented group of colleagues, both in Investment Management and throughout the Commission, during such a productive and transformative period in investment management regulation,” Mr. Cellupica said. “I am grateful to Director Blass for the opportunity of a lifetime to return to the SEC, and I am extraordinarily proud of what the division and the Office of the Chief Counsel have been able to accomplish, working as a team, on behalf of investors.”

Under Mr. Cellupica’s leadership, the IM Office of the Chief Counsel provided critical contributions to a number of important policy areas and initiatives, including:

  • COVID-19 Emergency Relief: Exemptive relief and guidance relied upon by nearly 700 investment companies, boards and advisers during the height of the pandemic, including relief from certain filing and delivery obligations, relief providing greater flexibility for funds in obtaining short-term funding, and relief permitting fund boards to satisfy in-person board meeting requirements through virtual meetings.
  • Board Outreach Initiative: Outreach to fund boards and trustees regarding ways to recalibrate board oversight responsibilities, resulting in the first Commission rulemaking to address fund valuation in 50 years, and staff guidance permitting fund boards to receive quarterly representations from the fund CCO regarding compliance of affiliated transactions with exemptive rules, instead of the board itself determining compliance.
  • Review of Staff Guidance: Initiation of a review of prior staff guidance, which has resulted so far in the withdrawal of over 70 staff letters and statements.
  • Actively Managed Non-Transparent ETFs:  Exemptive relief to permit novel forms of actively-managed ETFs, which operate without being subject to daily portfolio transparency.
  • Proxy Voting: Commission guidance for investment advisers on exercise of their proxy voting responsibilities, including use of proxy advisory firms, in conjunction with a broader effort to modernize and enhance the proxy voting system.
  • Innovative Exemptive Relief: Novel and valuable exemptive relief under the Investment Company Act of 1940, including relief to permit business development companies to offer multiple classes of shares; relief to permit fund boards to approve changes in sub-advisers at non-in-person meetings; expansion of multi-manager relief to affiliated sub-advisers; relief to permit a closed-end fund to pay advisory fees in fund shares as well as cash; and relief permitting a fund to use an alternative classification methodology in its liquidity risk management program.
  • Creation of IM Liaison Office: Transformation of the division’s Enforcement Liaison Office into an expanded office that partners with both the Enforcement and Examination Divisions, and has supported numerous Enforcement investigations and initiatives to protect Main Street investors, including the Share Class Selection Disclosure Initiative which returned over $139 million to investors.
  • Streamlining the Exemptive Applications Review Process: Changes to improve the process for review of exemptive applications, including adoption of a new rule that will create an expedited review process for exemptive applications that are substantially similar to recent precedent.
  • Guidance on MiFID II:  Extension of no-action relief issued in response to the European MiFID II rules on payment for research in Europe, including guidance regarding payments for research through Client Commission Arrangements (CCAs).
  • International engagement:  An enhanced voice for the Division in international regulatory discussions involving important policy issues such as ESG, the role of ETFs, fund liquidity, and fund investments in leveraged loans.

In addition, Mr. Cellupica had an important role in a number of significant rulemaking initiatives, including the adoption of rules permitting a “notice and access” method of delivering shareholder reports; revisions to the Volcker rule; development of a summary prospectus for variable insurance products; and the Commission’s interpretation regarding investment advisers’ fiduciary duty. He also helped lead the formulation of division policy on critical topics such as fund investments in cryptocurrency; investment adviser custody of non-traditional assets, including digital assets; cybersecurity; the transition from LIBOR; registered fund investments in private funds; closed-end fund governance; and investment company status issues involving operating companies.

Mr. Cellupica previously served in several leadership capacities in the Division of Investment Management and the Division of Enforcement from 1996 to 2004. Prior to rejoining the Division in November 2017, Mr. Cellupica was Managing Director and General Counsel for Securities Law at Teachers Insurance and Annuity Association of America (TIAA). Prior to that, he was Chief Counsel for the Americas at MetLife, Inc.

During his tenure at the SEC, Mr. Cellupica received the Martha Platt Award; the Law and Policy Award; the Chairman’s Award for Serving the Interests of Main Street Investors; and the Chairman’s Award for Excellence.

Mr. Cellupica received a B.A. magna cum laude from Harvard College and a J.D. cum laude from Harvard Law School. He served as a law clerk for Judge David Nelson of the U.S. Court of Appeals for the Sixth Circuit.

Upon Mr. Cellupica’s departure, Brent Fields will become acting Deputy Director and acting Chief Counsel of the Division of Investment Management.

Fintech

How to identify authenticity in crypto influencer channels

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Modern brands stake on influencer marketing, with 76% of users making a purchase after seeing a product on social media.The cryptocurrency industry is no exception to this trend. However, promoting crypto products through influencer marketing can be particularly challenging. Crypto influencers pose a significant risk to a brand’s reputation and ROI due to rampant scams. Approximately 80% of channels provide fake statistics, including followers counts and engagement metrics. Additionally, this niche is characterized by high CPMs, which can increase the risk of financial loss for brands.

In this article Nadia Bubennnikova, Head of agency Famesters, will explore the most important things to look for in crypto channels to find the perfect match for influencer marketing collaborations.

 

  1. Comments 

There are several levels related to this point.

 

LEVEL 1

Analyze approximately 10 of the channel’s latest videos, looking through the comments to ensure they are not purchased from dubious sources. For example, such comments as “Yes sir, great video!”; “Thanks!”; “Love you man!”; “Quality content”, and others most certainly are bot-generated and should be avoided.

Just to compare: 

LEVEL 2

Don’t rush to conclude that you’ve discovered the perfect crypto channel just because you’ve come across some logical comments that align with the video’s topic. This may seem controversial, but it’s important to dive deeper. When you encounter a channel with logical comments, ensure that they are unique and not duplicated under the description box. Some creators are smarter than just buying comments from the first link that Google shows you when you search “buy YouTube comments”. They generate topics, provide multiple examples, or upload lists of examples, all produced by AI. You can either manually review the comments or use a script to parse all the YouTube comments into an Excel file. Then, add a formula to highlight any duplicates.

LEVEL 3

It is also a must to check the names of the profiles that leave the comments: most of the bot-generated comments are easy to track: they will all have the usernames made of random symbols and numbers, random first and last name combinations, “Habibi”, etc. No profile pictures on all comments is also a red flag.

 

LEVEL 4

Another important factor to consider when assessing comment authenticity is the posting date. If all the comments were posted on the same day, it’s likely that the traffic was purchased.

 

2. Average views number per video

This is indeed one of the key metrics to consider when selecting an influencer for collaboration, regardless of the product type. What specific factors should we focus on?

First & foremost: the views dynamics on the channel. The most desirable type of YouTube channel in terms of views is one that maintains stable viewership across all of its videos. This stability serves as proof of an active and loyal audience genuinely interested in the creator’s content, unlike channels where views vary significantly from one video to another.

Many unauthentic crypto channels not only buy YouTube comments but also invest in increasing video views to create the impression of stability. So, what exactly should we look at in terms of views? Firstly, calculate the average number of views based on the ten latest videos. Then, compare this figure to the views of the most recent videos posted within the past week. If you notice that these new videos have nearly the same number of views as those posted a month or two ago, it’s a clear red flag. Typically, a YouTube channel experiences lower views on new videos, with the number increasing organically each day as the audience engages with the content. If you see a video posted just three days ago already garnering 30k views, matching the total views of older videos, it’s a sign of fraudulent traffic purchased to create the illusion of view stability.

 

3. Influencer’s channel statistics

The primary statistics of interest are region and demographic split, and sometimes the device types of the viewers.

LEVEL 1

When reviewing the shared statistics, the first step is to request a video screencast instead of a simple screenshot. This is because it takes more time to organically edit a video than a screenshot, making it harder to manipulate the statistics. If the creator refuses, step two (if only screenshots are provided) is to download them and check the file’s properties on your computer. Look for details such as whether it was created with Adobe Photoshop or the color profile, typically Adobe RGB, to determine if the screenshot has been edited.

LEVEL 2

After confirming the authenticity of the stats screenshot, it’s crucial to analyze the data. For instance, if you’re examining a channel conducted in Spanish with all videos filmed in the same language, it would raise concerns to find a significant audience from countries like India or Turkey. This discrepancy, where the audience doesn’t align with regions known for speaking the language, is a red flag.

If we’re considering an English-language crypto channel, it typically suggests an international audience, as English’s global use for quality educational content on niche topics like crypto. However, certain considerations apply. For instance, if an English-speaking channel shows a significant percentage of Polish viewers (15% to 30%) without any mention of the Polish language, it could indicate fake followers and views. However, if the channel’s creator is Polish, occasionally posts videos in Polish alongside English, and receives Polish comments, it’s important not to rush to conclusions.

Example of statistics

 

Wrapping up

These are the main factors to consider when selecting an influencer to promote your crypto product. Once you’ve launched the campaign, there are also some markers to show which creators did bring the authentic traffic and which used some tools to create the illusion of an active and engaged audience. While this may seem obvious, it’s still worth mentioning. After the video is posted, allow 5-7 days for it to accumulate a basic number of views, then check performance metrics such as views, clicks, click-through rate (CTR), signups, and conversion rate (CR) from clicks to signups.

If you overlooked some red flags when selecting crypto channels for your launch, you might find the following outcomes: channels with high views numbers and high CTRs, demonstrating the real interest of the audience, yet with remarkably low conversion rates. In the worst-case scenario, you might witness thousands of clicks resulting in zero to just a few signups. While this might suggest technical issues in other industries, in crypto campaigns it indicates that the creator engaged in the campaign not only bought fake views and comments but also link clicks. And this happens more often than you may realize.

Summing up, choosing the right crypto creator to promote your product is indeed a tricky job that requires a lot of resources to be put into the search process. 

Author Nadia Bubennikova, Head of agency  at Famesters

Author

Nadia Bubennikova, Head of agency at Famesters

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Fintech

Central banks and the FinTech sector unite to change global payments space

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The BIS, along with seven leading central banks and a cohort of private financial firms, has embarked on an ambitious venture known as Project Agorá.

Named after the Greek word for “marketplace,” this initiative stands at the forefront of exploring the potential of tokenisation to significantly enhance the operational efficiency of the monetary system worldwide.

Central to this pioneering project are the Bank of France (on behalf of the Eurosystem), the Bank of Japan, the Bank of Korea, the Bank of Mexico, the Swiss National Bank, the Bank of England, and the Federal Reserve Bank of New York. These institutions have joined forces under the banner of Project Agorá, in partnership with an extensive assembly of private financial entities convened by the Institute of International Finance (IIF).

At the heart of Project Agorá is the pursuit of integrating tokenised commercial bank deposits with tokenised wholesale central bank money within a unified, public-private programmable financial platform. By harnessing the advanced capabilities of smart contracts and programmability, the project aspires to unlock new transactional possibilities that were previously infeasible or impractical, thereby fostering novel opportunities that could benefit businesses and consumers alike.

The collaborative effort seeks to address and surmount a variety of structural inefficiencies that currently plague cross-border payments. These challenges include disparate legal, regulatory, and technical standards; varying operating hours and time zones; and the heightened complexity associated with conducting financial integrity checks (such as anti-money laundering and customer verification procedures), which are often redundantly executed across multiple stages of a single transaction due to the involvement of several intermediaries.

As a beacon of experimental and exploratory projects, the BIS Innovation Hub is committed to delivering public goods to the global central banking community through initiatives like Project Agorá. In line with this mission, the BIS will soon issue a call for expressions of interest from private financial institutions eager to contribute to this ground-breaking project. The IIF will facilitate the involvement of private sector participants, extending an invitation to regulated financial institutions representing each of the seven aforementioned currencies to partake in this transformative endeavour.

Source: fintech.globa

The post Central banks and the FinTech sector unite to change global payments space appeared first on HIPTHER Alerts.

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TD Bank inks multi-year strategic partnership with Google Cloud

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TD Bank has inked a multi-year deal with Google Cloud as it looks to streamline the development and deployment of new products and services.

The deal will see the Canadian banking group integrate the vendor’s cloud services into a wider portion of its technology solutions portfolio, a move which TD expects will enable it “to respond quickly to changing customer expectations by rolling out new features, updates, or entirely new financial products at an accelerated pace”.

This marks an expansion of the already established relationship between TD Bank and Google Cloud after the group previously adopted the vendor’s Google Kubernetes Engine (GKE) for TD Securities Automated Trading (TDSAT), the Chicago-based subsidiary of its investment banking unit, TD Securities.

TDSAT uses GKE for process automation and quantitative modelling across fixed income markets, resulting in the development of a “data-driven research platform” capable of processing large research workloads in trading.

Dan Bosman, SVP and CIO of TD Securities, claims the infrastructure has so far supported TDSAT with “compute-intensive quantitative analysis” while expanding the subsidiary’s “trading volumes and portfolio size”.

TD’s new partnership with Google Cloud will see the group attempt to replicate the same level of success across its entire portfolio.

Source: fintechfutures.com

The post TD Bank inks multi-year strategic partnership with Google Cloud appeared first on HIPTHER Alerts.

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