Video: How Comply Lightens the Load with Managed Services | Duration: 1808s | Summary: How Comply Lightens the Load with Managed Services | Chapters: Welcome and Introduction (24.59s), Employee Trade Monitoring (97.005005s), Implementation Challenges (416.515s), Key Monitoring Resources (626.19995s), Automated Reporting Features (865.985s), Compliance Data Services (1093.225s), Concluding Broker Feed Discussion (1532.55s)
Transcript for "How Comply Lightens the Load with Managed Services":
Everyone, welcome today to today's webinar solution showcase on our managed services and how Comply can help you lighten the load. I'm Allison Cooley. I'm our senior director of product marketing here at Comply. And before I introduce one of my favorite people here, I'm going to cover a few housekeeping pieces. So I know we've got a lot of clients on the call. Some of you might already know Brett. Some of you might already know me. We're so happy that you're here, and, we're going to be walking you through some of our managed services offerings here at Comply. If you have any questions after this event, I'll provide my information. I'll also be sending you a recording of this, and then you can reach out to your CSM or me or your account manager to learn more about some of the stuff that Brett's going to walk you through today. And without further ado, I am joined by Brett Burnett, who is our senior manager of support and services here at Comply, and he is the person to know. So he is going to get into exactly how we combine our technology and our services and our managed services to make your firm more efficient in key areas. So Brett, if you'd like to quickly introduce yourself, and then we can go through the slides we've got prepared today. Absolutely. Hi, everybody. Thank you so much for your time here today. More specifically, today, I'm here to discuss employee trade monitoring, which if you might not be aware, Comply is a bevy of different services and software solutions that we can offer. Employee trade monitoring is truly our bread and butter, if I do say so myself. So really today on the agenda overall, we are here to talk about a few key items. Number one, the importance of trade surveillance in our industry. Why we do it, why should we care, etcetera. Number two, we're going to talk about the common blockers that I see day in and day out. Those things that really inhibit teams from having a spotless employee trade monitoring program. After that, we'll discuss some general best practices that I've seen over the years that I'd love to recommend to you as partners of the Compli ecosystem. And last but not least, I'd love to talk to you about some of the services that my teams have that make your life easy and seamless as much as we possibly can. So moving right along. Number one, trade surveillance, employee trade monitoring. Why does it matter? Now, depending on whether you're a broker dealer or a registered investment advisor, there are a few reasons that you may need to take a closer look at what your employees are trading in their personal brokerage accounts. Number one elephant in the room for broker dealers everywhere FINRA Rule 3,210. That requires disclosure of personal trading accounts. It incorporates different aspects of the old NYSE Rule four zero seven for duplicate trading confirms and just general oversight of outside accounts. And then, of course, adjacent to that, Rule three one hundred ten. 3,110 drives that supervisory obligation to review personal trading, detect overall misconduct, and more importantly, enforce preclearance requirements. Then on the RIA side of the front, you may notice SEC Rule 204A1. That requires reporting of initial and annual holdings as well as quarterly transactions. And then there are other rules that are a little bit lesser talked about out there that I do want to make sure that is still top of mind for people such as SEA Rule 10B5, ITSA, and of course, ITFEA. Those all carry heavy implications around stuff like insider trading, fraudulent and incorrect reporting, which is a very common thing that many regulatory agencies tend to find firms on. So overall, what we do and what my main goal here at Comply is, is to make sure that our partners stay within compliance of all of this across the board. And we do this from a software perspective in one core part of our platform, and that is Comply's employee trade monitoring solution. So on the next slide, you'll see ultimately it's a one size fits all solution that is ready at the point of implementation in our software. We have a very intuitive AI that makes it easy for compliance teams to personalize their preclearance and post trade rules. It makes them easy to keep updated their restricted list, their blacklist, their graylist, their white lists, and creates automated preclearance workflows to match your firm's presence and preference. So in other words, whether you have a million preclearance requests going on throughout the day, whether you only need to carry about post trade validation, or on top of that, whether you want us to handle your pre clearance requests automatically through our automation systems, or if you would prefer to have that human element of manually confirming, approving, or denying those requests, this solution out of the box is ready for you. We have a very deep and robust partnership with well over 300 brokerage firms, both in The US and internationally, that allows clients trade data to be updated daily for a very large percentage of the overall monitored employee population. And to just add icing on the cake to it all, real time notifications that allow compliance teams to act quickly and follow-up on any potential trade violations or unmatched trades that may occur within the system. And as today's regulatory body continues to change and evolve, one thing that I've gotten plenty of questions about over the years is what is Comply doing around cryptocurrency? Happy to say that we can also monitor that stuff as well. We do have those solutions for cryptocurrency trading, and those are available to ensure that your entire employee trade monitoring solution remains current and entirely future proof. So we have a whole host of different solutions to fit those needs. Now, this all sounds fantastic. We love out of the box solutions. We love easy plug and play technology. But there are always some blockers and some things that prevent these firms from implementing it successfully. So I wanna talk about a few of those today as well. Now, the first thing that I will tell you, every broker, when it comes to establishing these broker feeds, has different rules, engagement, policies, etcetera, in terms of getting these feeds set up. Oftentimes, it can take a very, very long time for these things to get established. Those long turnaround times for broker firms to establish those feeds creates a large barrier to entry for a lot of firms when it comes to getting an employee trade monitoring solution that is holistic. Most of the time, those feeds can take a little bit, and it is very important if you're the one that is kind of that point of contact between the firm that you work for and those brokers you're trying to establish those broker feeds with. It's very important to stay on the ball and have a great sense of project management whenever you are establishing those feeds. Number two, staying on top of newly disclosed brokerage accounts. Most firms, whenever they get set up, they have this, for lack of a better word, a set it or forget it mentality to their broker feeds where they get all this work done, they have these broker feeds set up, all their accounts are feeding. That's awesome. But then John Smith, onboards at your firm, discloses a handful of new accounts, and you might not be thinking about it. All of a sudden, you now have three, and that snowballs into five, six, seven accounts that you are not monitoring for in that moment. So a lot of clients struggle with taking the required actions not only to establish a feed, but to add accounts to a feed after new accounts have been disclosed. When this is a leftover all fester, severe risks begin to arise to your firm. And then common blocker IC number three is when there are separate locations and policies for storing statements. Now, of course, we do have a lot of broker feeds available, but in those instances where there is not one available, oftentimes many firms resort to the tried and true paper statement route, manually checking those brokerage statements that they may receive from the broker that the employee may be providing to the firm to make sure that no potential misconduct had occurred. However, when that occurs, many, firms tend to keep those statements housed in an area that is separate from where these electronic data records are being stored. This discrepancy in where those documents and where that information is being housed creates ultimate discrepancies and potential gaps for risk within your monitoring and your reporting platform. So all that being said and done, taking these three blockers into consideration, I would love to present you all with just a few recommendations that I have, easily summed up in the next slide. As you step towards a more airtight employee trade monitoring program, we have a whole ton of pages, resources, etc. To help you effectively monitor, maintain, and improve upon this program. Best way to identify gaps in your program and begin to fill them is by leaning on a handful of key resources. Number one, the Comply Resource Center. If you are unsure of where to go to to find out how to get an account feeding, that page should be your one stop shop. Number two, to make sure that data and paper statements are being housed in a centralized location, Comply's statement tracking report is there to help. Number three, if you need to understand what newly disclosed accounts that you can get to an electronic feed, we have a very robust broker feed status report waiting for you. And then number four, all this data is great, but how do you report on it? Very happy to say that Comply's platform has automated reporting mechanisms where you can truly set it and forget it. So moving right along, let's talk about that Resource Center and why that's so important, so helpful. I could talk about this all day as somebody that lives inside and outside of this particular website. But the Compli Resource Center itself gives you access to a full directory of those over 300 brokers that we have electronic feeding capabilities with. And on top of that, even if it's not employee trade monitoring related, we have well over 1,000 individual help articles and videos within there that are designed to help you achieve specific goals within the platform. You can also use that broker fee directory that you see to verify that account numbers are correct. You can use it to get contact information for a given broker. You can use it to review important forms and documentation, potentially even have it filled out before you even reach out to the broker. And we give you the lay of the land, helping you understand exactly what that broker's unique process is when it comes for adding and or establishing feeds or accounts to a feed. Now, resource number two I would love to make you all aware of is that broker feed status report. It is a page innately in your reporting module on Comply that helps you visualize what accounts are feeding, what can be configured to feed, and what accounts could cause those potential gaps in your monitoring. It'll break every account in your Comply platform down to one of four key statuses. Number one, sending broker data. That is your sign to note. Comply has your back. Those accounts are feeding. The moment an employee trades on there, that trade will exist in your data records, ready to go for you to test. Number two, no broker fee available. That's a key indicator for you to know, hey, we're going to have to monitor this employee's trading activity some other way, most commonly that paper statement route. Number three, invalid account number. If an employee incorrectly disclosed an account in Comply's platform and we know exactly what the format of that account number should be based off the broker, we're going to be proactive and automated and let you know about that ahead of time. This page allows you to easily visualize that as well so that you can keep the cleanest records possible. And last but not least, accounts not sending data. Those are your accounts that are not feeding today, but they very well could be. And those should be your prime target to access that broker fee directory we just talked about to begin those conversations with those brokers. Now, item number three that I touched on and talking about those accounts that can't feed, the statement tracking report. Our statement tracking report allows you to collect, track, and review paper statements for any accounts that aren't feeding or can't feed. This is a perfect solution to keeping your data records exactly in the same location as you house those physical documents. So the statement tracking report allows you to review those non feeding accounts and automatically chases down those pesky employees to upload their statements. You get to choose the frequency at how often these employees upload those statements as well, by the way. So whether you prefer your employees to provide those statements on a monthly basis, a quarterly basis, or more commonly for managed accounts and stuff like that, an annual frequency, we can do that for you. All the while letting the employee know when it's time to upload a statement and being what I like to call pleasantly persistent in making sure that those employees do actually provide that documentation. What is the icing on the cake in this module for me personally is the fact that it easily visualizes and simply visualizes all the accounts and months that statements are required for to give you a very easy explanation of what statements are still being waited on, whether or not a given statement has been reviewed, or whether or not one is even required given the circumstances around that account. So we are taking all of that stress off of you to make sure that your employees and your firm have provided the statements that you all need to. Last but not least, I wanted to talk about that really nice automated reporting. This is something that I screen from the rooftops and very few people take advantage of this. So I want to implore you to take advantage of it for yourself. We have an automated reporting module that generates the reports you need as often as you need them. Our reports module allows you to not only generate those reports for yourself ad hoc, but also allows you to save it. And for those saved reports that you need time in and time out, whether that be weekly, daily, monthly, quarterly, you name it, you can schedule it to auto generate. Those reports that are able to be auto generated include information like newly disclosed accounts so that you can, again, more proactively identify those accounts that you want to monitor for. That also trickles down to the transactions that may not have been pre cleared so that you can help fine tune your own employee trade monitoring solution and maybe even take a look and say, hey, we can exempt this security or exempt this security type from preclearance. And then last but not least, also preclearance outcomes. If you want to run an audit on an average basis, maybe annually, quarterly, what have you, you can set that reporting module up to tell you exactly what pre clearance requests went through your system and how the system behaved for each request. So whether it was approved by the system, whether it was denied by the system, or whether or not the system pushed the request to a human being for a manual approval, you get that information and allows this entire program allows you to more accurately determine whether or not there's something to fine tune, implement differently, whatever the situation may be. Now, all of this is fantastic. It's robust. But there are still some gaps that need to be filled. Not every firm has the time or the ability to take all this on at once. That is exactly where my team comes into play. Compliance Data Services teams serve to ensure that there are zero gaps in your firm's employee trade monitoring program, mainly through two different services. For one, broker fee maintenance. Instead of you reaching out, handling those conversations with the brokers and all the back and forth that comes with that, my team can do that for you. We also monitor your platform for those newly disclosed accounts so that you can always rest assured every single time that you onboard a new employee, or if a preexisting employee discloses a brand new account, we're already aware of it and we're already in conversation with those brokers to get those accounts up to feed for you. And for those accounts that cannot feed, we have a manual data entry department here as well. For those accounts that can't feed, we will convert those transactions and holdings found within the employee brokerage statements into those transaction and holding data records. Our overall mantra when it comes to manual data entry itself is simply, we want to look and feel as if we're a broker feed in and of itself. And so at the end of the day, with that service, you get that confidence to know 100% of your data looks the same. It's standardized and it's timely. Now talking about each service a little bit more, granularly. So unpacking data services, very, very quickly. I want to talk about the manual data entry service on a deeper level. By the numbers, Comply's manual data entry team has processed over 314,000 unique statements since the team's inception. And across those 314,000 statements, that is across 33,900 unique accounts that we have monitored. And that itself is across over 170 and counting firms that use Comply's manual data entry services. All of that, mind you, is also across 3,627 unique brokers. I want to touch on that for just a minute because 3,627 brokers with different structured formats, different data that they glean, different identifiers, that is a huge value add because even some of these statements, most I would argue, are international. Yes, COMPLY's manual data entry team has the ability to translate non English statements. We have extensive history in Korean, Japanese, Mandarin, Cantonese. Any languages that you may be receiving statements for, we are perfectly capable of processing. And that is something that not everybody can say. Now, on top of the numbers, what we are doing for you a little bit more granularly, we are proactively monitoring and tracking those statements that become uploaded in the Comply platform. Those statements are automatically notifying us when there is a statement to review, making this solution a true set and forget moment for you. You do not need to tell us when an employee has uploaded a statement. We know about it. The moment that statement gets uploaded, there is a blip on our radar and we are already working to get that on deck and ready to process for you. All this data that is entered by the COMPLY manual data entry team is cross referenced and checked against your trade preclearance rules, allowing you to receive those same notifications of potential violations in unmatched trades that you would have otherwise have received if it were fed in via a broker feed. And we have multiple different options for you. Whether you prefer digital, aka employee uploaded through the Comply platform, or whether you would prefer for the broker to duly mail those statements directly to Comply, we're able to accommodate that so that no matter what terms we're on, we're always able to work on yours. And then let's talk about broker fee maintenance a little bit more. The broker fee maintenance team has serviced well over 12,000 unique communications in order to establish broker feeds on behalf of our clients. Collectively, that is nearly 71,000 accounts that we have successfully added to feeds since the team's inception. And talk about experience. We have well over twenty years of combined experience when it comes to broker feeds. That means that you'll never get the I'm not entirely sure answer from us. We are the de facto experts on all things broker feeds, brokers, and COMPLY. And over 167 and counting clients are currently using that service today. Now, how do we operate along that front? Compli's data services team begins by performing an initial scan of all of the accounts that are currently disclosed in your system. With those that can't feed, we immediately get to work with that broker to confirm that they can feed and get them up and running for you. Not only that, you are assigned one of these data services specialists. So you receive a dedicated broker feed expert that is tasked to keep you organized with any forms, whether that be four zero seven letters, individual letters of authorization, three thousand two and ten letters, whatever comes about, we're there to keep you organized and make sure that you know what needs to be signed and when. And in perpetuity, after all the broker feeds that can be connected have been connected, we pivot to more of a proactive monitoring stance. We are daily checking your site to make sure that there are any new accounts that are disclosed and that we are actioning on any of those accounts that might come about. Or if something falls off a feed because there are no holdings or activity or if the account's been liquidated or if they're all of a sudden, one day, it's just all cash in it, we're double checking that stuff too so that you know exactly why an account is not feeding, if ever one appears. So you have that peace of mind to know day in and day out that your broker feeds are being treated with a great amount of care. And in those situations where one might not exist, we are making sure that you still get 100% of the data that you need in order to operate and keep your firm safe. So those are the solutions we have. I would love to see if there are any questions about any of this. But most importantly, thank you all for listening to me talk for the past few minutes. Yeah, Brett, thank you so much. I was so tempted to interrupt you a few times during it. Firstly, I love how you walked everyone through the stuff, if you're a client, that you already have, right? And so we, as, you know, humans at work deal with a lot of technology, we are not, you know, thinking the only technology that our clients are using our own. So it's really hard to kind of remember all of the availability within a technology system. So, like, those different reporting mechanisms, if that's something you've been using, please let our team know. Let us know. Let your CSM know. We want to help you help yourselves. Right? But on top of that, you know, I look at this from, like, a firm wide strategy of, like, deciding who who your employees are allowed to trade with. Right? Because there's some firms that it's too much to allow them to trade with any brokerage, right, because of the manual work of it all. But you also want to be able to provide your employees with the ability to invest their money how they want to invest it, right? And so, if you're a firm that, you know, Air is on, we want to be able to offer more to our employees, managed services is a really great resource for those accounts that we don't already have directly feeding, right? But I want to ask you one question. You know, we talked a lot about our clients, but, you know, for those who are on the call that are looking at Comply and they're very interested in our broker feeds and kind of these service capabilities, I would love for you to share a little bit of color around what makes our broker feeds great to begin with before your team even comes in as others evaluate broker feed aggregators or challenges where employees are one to connect through something. If you could share that with us. Absolutely. I would say compliance strength in broker feeds spans two different items. Number one, just the sheer breadth. I've mentioned it before, but having over 300 broker feeds and having that amount both domestic and international is a huge value add to any firm, particularly those that might be multi jurisdiction. Separately from that, I would argue that we have an incredible uptime as far as our broker feeds are concerned. Over 99% uptime over the past handful of years, which is a very difficult thing to do, especially knowing as far as the, let's call it the technical qualifications and requirements that are needed to make a broker feed operate, having that uptime is something that really makes us stand out and a true differentiator in this market. Thank you so much for joining us today. And I have my teams in the chat and the comments. We'll have some solution sheets. We'll have more materials and more to come here. But you know how to find us. We'll be reaching out. And Brett, thank you, and we'll see you on the next one. Of course, thank you all for your time.