A Culture of Compliance

OTR has not only built a compliance structure that rivals the best on Wall Street, it has also developed a culture of compliance that starts at the top and permeates throughout the firm.

OTR’s emphasis on compliance is evident in the firm’s:

Business Practices

  • OTR does not pay sources to participate in the firm’s written research.
  • OTR requires its reporters and editors to clearly identify themselves to sources as OTR personnel and disclose that they are conducting research on behalf of institutional asset managers.
  • OTR requires its reporters and editors to notify all sources that they may not provide material non-public information (MNPI) and other confidential information to us, and to document having done so.
  • Sources are offered copies of the research report in which they contributed.
  • No direct source attribution exists within OTR’s research products.

Elevated Compliance Standards

  • OTR’s reporters and editors must follow OTR’s strict guidelines concerning MNPI and confidential information. It is OTR’s duty to refrain from publishing any information that may breach a source’s duty of confidentiality to any party, including their employers.
  • Reporter attestation to the above briefing is required before any source data is incorporated in any OTR report.
  • All research is reviewed and approved on multiple levels prior to client distribution.
  • OTR is a California registered investment advisor.
  • All OTR employees must attest to participating in the firm’s Annual Compliance Meeting.

 Investment in Technology

  • OTR invests significant capital in technology each year (a material amount for a firm of OTR’s size).
  • Advanced technology permits OTR to track and monitor its communications and business activities. 
  • OTR conducts its Annual Compliance Meeting virtually to ensure the full participation of all employees, who are located internationally and throughout the United States.

Since 1995, OTR has conducted unbiased marketplace research for institutional investors, built upon an ethical framework of journalistic principles and a comprehensive supervisory structure that is applied throughout the firm’s research process to ensure compliance with U.S. securities laws. The various elements of OTR compliance structure combine to build a robust supervisory framework that has stood the test of time.