Name: illumis Solution Showcase
Uploaded: 2026-01-29T16:46:12.325Z
Duration: 30 min 12 s
Description: illumis Solution Showcase

Transcript for "illumis Solution Showcase": Hi everyone, and thanks for joining today's session on pay to pay compliance. I'm Trent Lanning, Product Marketing Manager here at Comply, and I'm joined by Oren Arbogast. Oren, would you like to introduce yourself? Thanks so much, Trent. My name is Orin Arbogast, and my role here at Complia is Solutions Engineer. I've been here going on six and a half years, and I've helped many clients like yourself who have pay to play concerns. I look forward to speaking with you today. Awesome. Thank you, Orin. Let's jump right into this thing. Now, before we get into today's session, here's a quick overview of comply. You may know us for solutions related to code of ethics and monitoring conflicts of interest. Really, we give firms a complete view of compliance from daily employee oversight to firm wide governance. We bring compliance technology, consulting services, and education together in one place with the goal of helping you build a stronger compliance program. Now, today, we're focusing on political contributions. We'll cover today's pay to play rules, common challenges associated with pay to play compliance, some best practices to optimize your program, and then a look at our Illumis solution designed to make this process a whole lot easier. Alright. So from the outset, I think it's important for us to remember why these rules exist in the first place. Why are we here today? Why do our firms have to deal with pay to play requirements? Ultimately, it's the need to protect the integrity of public investing. It's about avoiding situations where advisers receive favorable treatment from the government, particularly via contracts, as a result of making political contributions. It's about mitigating conflicts of interest and ultimately preserving public trust. Now, what makes compliance difficult? Well, from a high level, why is this sort of compliance really challenging? A big reason is that it's an inherently fragmented responsibility. Pay to play rules don't always align cleanly with one another. What's okay with one locale may not be okay with another. Not to mention the data for political contributions lives across databases, something you're likely familiar with if you're already tasked with monitoring contributions. More on that shortly. But rounding things out, enforcement isn't just limited to actual bad actors. Insufficient monitoring and oversight, even if it's just because of resource limitations, can result in enforcement actions too. Now we'll touch on the rules. First up, the one most people are familiar with, SEC rule two zero six four-five. At its core, this rule is very simple in concept. Advisors cannot use political contributions to win or keep government clients. Where it gets complicated is in how broadly the rule applies and how little room there is for error once it's triggered. First, who's covered? Covered associates include executive officers and managing members, employees who solicit government clients, and even PACs that are controlled by the adviser or its covered associates. Next, what actually triggers a timeout? So a timeout is triggered by a contribution to an official or candidate who can influence the selection of the adviser. The contribution doesn't have to be large, and it doesn't require proof of intent. If the official has influence over the decision, the rule is in play. And the consequence, once triggered, the firm faces a two year prohibition on receiving compensation from that government entity. You'll notice the note at the bottom around de minimis exceptions. These allow for small limited contributions, typically $350 if the contributor can vote for the official or $150 if they can't. But these thresholds are narrow and easy to misapply, especially once state and local rules are layered on top. Now let's shift from the SEC to the MSRB, which governs pay to play risk in the municipal space. MSRB rules G37 and G42 address the same core concern as the SEC rule. First, who these rules apply to? They apply to broker dealers engaged in municipal securities business and to municipal advisers. They also extend to individuals inside the firm, especially MSPs and MAPs. Next, what triggers a timeout? A timeout here is triggered by a political contribution to a municipal official who can influence the award of municipal securities or advisory business. As with the SEC rule, the contribution doesn't need to be large, and it doesn't require intent. If the official has influence over the decision, the restriction applies. And the consequence is significant. Once triggered, the firm faces a two year prohibition on municipal securities or advisory business with that municipal entity. You also see the note at the bottom regarding rule g 42. This is important because it reinforces that pay to play controls aren't standalone. Municipal advisers are required to identify, manage, and document conflicts of interest, including political contributions as part of their fiduciary and supervisory obligations. Now pivoting to state and local pay to play rules. These often go further than federal requirements. First, who sets these? Well, they can be imposed by states, counties, cities, public pension plans, and other government agencies. In some cases, they're tied to specific industries or even specific contracts. That means firms aren't dealing with one standard, they're dealing with many. Second, why these rules are often more restrictive. State and local regimes frequently use broader definitions of who's covered, apply lower or even zero de minimis thresholds, and extend look back periods. Some also link restrictions directly to bidding, contracting, or licensing activity. So what does this mean for firms? Well, federal compliance alone is not sufficient. Firms need to assess pay to play exposure by jurisdiction because local rules can independently restrict business even when the federal rules are satisfied. Diving a little deeper into this, so a contribution can be fully permitted under federal rules and still violate a state or city pay to play rule. Here's a common scenario. An employee makes a contribution that's allowed under SEC thresholds. That same contribution violates a city or state pay to play rule. Once that happens, firms can lose eligibility for local government business. Now, where does pay to pay compliance most often break down? It's when we see contributions made without preclearance, indirect activity from spouses or packs that isn't captured, and manual tracking that's burdensome across jurisdictions. The key point is this. The contribution itself isn't the only risk. Your firm also needs to know that it happened in the first place. So let's be frank, even when you know what to look for, manual oversight just doesn't really scale. Political contribution data is extremely fragmented. It lives across federal, state, and local databases, often with dozens of separate sites that may need to be checked depending on where you do business. Those searches are inconsistent and time consuming. Databases work differently, use different formats, and sometimes require different search logic. And finally, documentation is hard to standardize. When reviews are done manually, it's difficult to show consistent processes, timing, and decision making across the firm. All right. Now all of the challenges aside, it's not all doom and gloom. There are a host of ways to simplify and strengthen the way you handle pay to pay compliance. First up, assess your policies. Do they clearly define who is covered, what contributions are restricted, and which federal, state, and local rules apply? Next up, having solid preclearance workflows. When it's easy and intuitive for employees to preclear their requests before they donate, you're better positioned to catch things early before they become a bigger problem. Then there's ongoing monitoring. Ongoing monitoring against public contribution data helps firms identify undisclosed or historical contributions that could otherwise go unnoticed. And finally, documentation. Ultimately, when you have all of the aforementioned things clearly organized and documented, you're putting yourself in a better position for exams. Alright. This is where we transition from the problem to the practical answer. Illumis, compliance political contributions monitoring solution, gives compliance teams visibility across federal, state, and local contribution activity. It's a game changer for pay to pay compliance. And with that, I'm gonna hand it off to Orin for a look at Illumis. Thank you so much, Trent. So I've begun sharing my screen, and you'll notice, I'm displaying the database page here. And that's one of the key points that you need to understand when it, when you're working with Illumis is it does work like a name database. So you have the first and last name, as well as some geographic filters of your covered associates that we will store in our database. And then using those details, we will do contribution lookup across 200 different, state and local databases to pull any contributions associated with those names using the filters that I've just mentioned. I've got Melinda Gates here as an example. I've gone ahead and clicked into her, and you can see I've already applied a couple of filters. Gonna go into a little bit more detail here, though. So I've given Melinda you know, I've I've listed her first and last name here. I've applied some geographic filters. So I've asked for individuals who have that name, live in The United States, sorry, who live in the state of Washington rather. If I left this blank, it would do a lookup across all 50 states. I could also narrow it down to ZIP code, which often we will recommend that you include if you are using this service. However, with Melinda, she uses a few different addresses and ZIP codes. So rather than restrict it, I've I've gone ahead and and left that blank. You'll also notice as part of the geographic filters, we've got exclusion address. So if there are addresses that you're seeing in the data records that you know don't belong to your individual person, you can have the software automatically exclude those. You'll notice we also have a tab here for alternate names. This is nice functionality, but you only want to use it if it's a thing. Unlike the geographic filters, which will winnow the results, the alternate names filter, this will expand the results. Melinda does often use the name French, so I've gone ahead and said, include that as a potential last name. Another example, using a first name, I have a client whose legal name is Martin, but when he gives contributions, he uses the name Marty. So in his Illumis instance, I'm doing a lookup on that alternate name of Marty. You also have occupation, employer, and occupation filters that are available. You can link an employer to someone's name. You can also exclude an employer. The use case for this is perhaps I'm a new hire to your firm. I come from another financial services firm. I've already been through the new hire process. They've already looked at my contributions over the last two years as required by the SEC regulations. So you already know about those. You don't want to see those. So exclude that prior employer, just include the one linked using the current employer. Another filter that you have available would be occupation, and this is only if it's given at the time of contribution. Often I do see this being included. Perhaps you'll see Melinda Gates enlisting the occupation as dentist. That could be another filter exclusion filter that you use to help ensure that you're not receiving false positives. Moving on to the last tab here, I'm gonna showcase the sources. And so you'll notice 199 different, again, and local databases, also at the federal level. I'll just mention we do have the District Of Columbia. At the federal level, of course, we're going to look at the most recent political action committees for the recent administrations. We also have the data source IRS Form 8,872. That's where individuals can declare contributions as part of their tax returns. We are capturing that as a data source. I will say, I've had more than one client have an moment related to those particular records. Just to showcase an example, depending on the state, we may or may not have additional databases where we drill down into. For example, with Alabama, it's just the one state database. But if I click into California, there are all kinds of county, municipal, and other databases that we're pulling from. On that note, I will say that the way Illumis gathers the data, it logs into these databases as if it were a user, and it pulls really high quality data. This is not data that's being screen scraped like other solutions. So we've talked about the names and filters, and I will say that's one of the big advantages for Illumis. Prior to our acquisition, we did do market research, we discovered that Illumis has the broadest and deepest access to this political contribution data out there. You'll probably notice there's a company's database. That would be where you could do a lookup based on an individual's employer. We're going to skip that as part of today's example, but this functionality works similarly as to a name lookup. I'll now turn to the dashboard, and this is the landing page that you will see when you log into the Illumis software. Here is a list of the political contributions in reverse chronological order. And you can see here, we'll just take an easy example, Melinda Gates. Here's the date of the contribution, the amount, the employer that she reported. As I mentioned, in this case, she's indicated founder, so that could be a filter that we use. The recipient is Maggie's List, which happens to be a political action committee. You'll notice I'm hovering here, and there's a spot for if if this were a candidate, we would fill in the additional details here. So let me show you this Joe Nagous for Congress. So in this case, I can hover here. We're going to give you some metadata about that individual. Already, you're getting some value out of just some quick hovers using the Illumis platform. We've got a status column here, and you'll notice these are defaulting to to do. You have things like approved, not approved, to to to to. These are ways you can status these records as you review them. You'll also notice there's a pre clearance request column. If I had matching pre clearance requests for these records, the system would show me those potential matches and allow me to reconcile them. That action takes place automatically, so if you're using comply in conjunction with Illumis, that reconciliation will happen. You can easily see what matches and doesn't match without you having to do that manual comparison. Later in the demonstration, we're going to have a specific example that showcases that. The other thing I'd like to mention while we're here is, you'll notice Maggie's list got a hyperlink here. I'm going to go ahead and click that. In this case, it's doing a lookup on this committee within the, FEC database. It's showing me here are the individuals who have given to Maggie's List. I could click around using this date, this site to filter, look at more additional detail, look at different dimensions of this. But I do like that feature, where we are going to not only tell you about the contribution, we're gonna link you and show you additional details. So specifically for contribution specific details, rather than just the committee, we can click the date link. And in this case, here here you go. It's gonna bring us to the the actual filing of this contribution. I can click in and see additional details here. I can even look at an image of the contribution or sorry, of the rather, not the contribution, the paperwork, the filing from the committee. So you could see here's that contribution. So many clients, in addition to using the reconciliation part, they use the software to do research into understanding why people gave or who the recipients are, things like that. So it's that research aspect to the external links that that also provide value. When you're using Illumis, it functions like a database. You load the names of your covered associates in there. On a daily basis, then Illumis will do a lookup, and it will look for any contributions since you know, that have happened since the last time it looked. So it will ingest those, and then you can choose the frequency, that you receive an email digest of those. Generally, clients do it on a weekly basis. Here you go, Orin. Here are the contributions related to your covered associates. When you're using that reconciliation functionality, the email that you receive will also include results of that, reconciliation. Why I call that out with the daily lookup is that enables you to have the longest cure runway if there are any issues with your contributions. A lot of clients find value in the fact that as soon as a jurisdiction uploads their contributions, the state of New York, whatever county in Alameda County in California, what have you. As soon as those contributions hit the database, Illumis will alert you. And again, that'll maximize your cure runway for any issues related to those contributions and any pay to play concerns. One item I neglected to mention related to the people database that I wanted to showcase is you have the ability to link spouses and dependents within that individual's record as well. So you've got the filtering. You can link dependents if that's covered by your code of ethics. You can also use taggings. Maybe she's on the board of directors or works in the New York office or some affiliate, etcetera. You can use tagging within Illumis to track your employees within their profile too. The last thing that I will mention go back to the dashboard here. You'll notice there's this insights button. I can click click that, and the software is gonna show me some granular detail about, volume of contributions by month, helping you potentially plan your workflow, see, you know, what what rhythm your employees are giving in. Obviously, we generally see spikes around primary and general elections, contributions by status, who the top recipients are, as well as who are the top givers. Again, immediate insights into your data. All of these panes are exportable into Excel, just as you see them now. If you need to pull reporting together, we also enable that within a click. I will just end on, the dashboard here, and I will mention that in regards to the other functionality that you've seen here, you do have the ability to add notes, attach documents about the contribution. Illumis, from being a database, using the filters, doing the lookups, matching the contributions against pre clearance requests, enabling your research, enabling notes, That's the whole three sixty degree functionality of the Illumis platform. Thank you very much, everyone, for your time today. Thanks, Orin. That was really helpful. So today, preclearance activity and comply can be brought into Illumis, allowing teams to compare what employees disclose with what appears in public contribution records. That makes it easier to catch discrepancies early rather than uncovering them later during an audit or exam. When issues do arise, Comply's case management helps teams document reviews, decisions, and resolutions. Here's an example of that. All right. So here we are in the Illumis platform that you just saw Orin in. Now I'm going to show you something interesting. So we're here in Illumis and we see new contributions. So we're going to go ahead and investigate these. So this one has a match. That's a good sign. We're going to take a look at this one here and we see that boom, it's already been pre cleared. That's a good sign. And in this case, this user pre cleared via the Comply platform integration into Illumis. So we'll go here and we'll see that this other contribution doesn't seem to have a match. So we'll take a look here. And after investigating and looking around, we see that there was no pre clearance request ever filled out for this particular contribution. In this case, because let's say our firm requires every political contribution to be documented and precleared, well, this is a problem. That is a violation of our firm's policy. So what we're going to do is we're going to jump over to the comply platform and we're going to create a case in this person's profile. So we'll click here, create a case in the comply platform. And this is where we fill out the details associated with this case. This particular one, it's a pre clearance violation within political contributions. We have options to note the severity level of this and to provide a description of what occurred. Eventually, if we do come to a resolution, we can also document that here. If you don't have a resolution at the time you're filling this form out, that's totally okay. You can jump into the case management anytime. You can jump into this portal right here. And what you'll see is an ability to edit and make changes, complete the case, all that here. So after we file out the after we complete these initial details, we can run down here and we can put in notes. We can write a description, the resolution here, all that good stuff directly within the compliant platform. Alright. So this connection will only continue to deepen. Illumis is being integrated into the Compli platform, which will give compliance teams an even more unified view into compliance activity. For Illumis clients, that means access to a 360 degree compliance platform built to support your entire program, from certifications to trade monitoring to advanced reporting and beyond. For Comply platform clients, that means access to what you've seen today, rich political contributions data and monitoring that streamlines your pay to pay compliance. Many thanks to everybody for attending today. We're really excited about the integrations coming to the Comply platform. If you have any questions, please feel free to shoot them my way. My email is tlanningcomply dot com. That's t l a n n I n gcomply dot com. Thanks again, and we'll see you next time.