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6. Disclosure: Disclosure continues to be critically important to the value we
deliver to our clients. In an effort to reverse declining disclosure rates, we are
continuing the implied disclosure method employed last year, using an “opt out”
rather than an “opt in” construct. There are few key points that you’ll need to
know for NAFIF fielding:
a. The “default” option for disclosure is for the buy-side client to have fully
disclosed his/her responses
i. For news and past disclosers, we think it will be safe to use the
default full-disclosure option. You will not need to ask for explicit
disclosure in these cases, unless the Buy-Side Client brings up
the issue in which case you should discuss it with them.
ii. For those who have not disclosed in the past, or who bring up
the subject of confidentiality during the interview, we would like
you to have a discussion about their objections to disclosing
iii. This discussion is noted in the Confirmit QAR, and begins with
your asking the client what their concerns are
iv. Explain that most investors allow us to share their individual
responses with senior management at fixed income dealers, so
that they will know which improvements in sales, trading,
research, or new issue allocations they should be making to
deliver a better service proposition
b. We have been working very closely with our sell-side clients to eliminate
instances of disclosure breaches and have added extra explicit
language in our contracts covering disclosure
c. This should be a discussion, and we really need to have these recorded,
so that we can analyze the response
d. The word “disclosure” can be scary! As we’ve discussed with many of
you, the wording is critical, and can mean the difference between a
rough and a smooth conversation. While we call it disclosure, the buy
side client need only think of it as “sharing their individual responses
with senior management.” Those EIs with the highest rates of
disclosure under the current methodology do not bring up the word
“disclosure” during the course of the interview.
e. The key to this approach will lie in your ability to communicate the safety
and value of shared responses, while at the same time understanding
the individual buy-side client’s disposition.

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