From prep-work to software, five steps to a more efficient and more effective process
Certifications can be intimidating, whether you're the person completing one or the person making sure they get completed. Getting everyone on both sides through to the other side of the process confidently, efficiently, and in full compliance with SEC regulations is the goal of any compliance team. The key word here is process. Approach certifications as a deliberate and calculated process and the hurdles common to this inescapable fact of enterprise financial institution life can be overcome.
Prepare, prepare, and then prepare some more. Like in any significant undertaking, many of the things that can go wrong in an involved process like certifications can be headed off with thoughtful, thorough planning. Time spent preparing now will be time saved later not fumbling and scrambling to fix things.
- Policy Changes—On the regulatory side, have there been any changes since the last round of certifications that will affect this round?
- Lessons Learned—On the company side, is there anything you should change based on the results from the last round?
- Verify Recipients—An absolute basic that's quite easily overlooked. Verifying recipients now means easier reconciliations later.
- System Updates—Now's the time to update alerts, dates, or certification language as appropriate.
- Pre-Cert Notification—Now's the time to consider sending out a pre-cert notification. "This is coming. Get ready for it."
- Training—Never to be underestimated, especially if it's agreed that certs can be intimidating. Consider classes or at least a Q&A session.
- Broker-Dealer Feeds—Are your feeds complete? Good broker-dealer feeds and fully-automated compliance software will make the certs easier to complete.
- General Awareness—How do you want to publicize this? A reminder on the compliance platform dashboard? A blurb on the office TV system or company message board?
- Due Dates—How far before the regulatory due date do you set your due date? People go on holiday or have work travel and can legitimately miss the cert period.
This is listed as phase two of the certification process, but it's still part of the preparation to the actual issuing. This is where you put all your thoughtful, thorough planning into action: at least in a controlled, limited manner. Testing can go a long way in heading off problems in the certifications process.
- Self—Review and program all of the above factors and considerations and send the certification sequence to yourself. This is your first opportunity to hone the actual issuing.
- Compliance Team—Now inflict your grand strategy on another set of sharp, seasoned eyes. This is your second opportunity to hone the actual issuing.
- Control Group—Now it's onto a batch of test users: a small group of reliable employees who will be receiving the final certs. This should leave you with a well-honed sequence.
This is where the rubber meets the road. You've done your homework, done loads of testing, and have a sequence that's as well-prepared and well-considered as it can be. But even the best laid plans can't account for everything. As the certs go out, expect some chaos and confusion to come back in.
- Issue Date And Time—This is the day and time you actually issue the certs, and gets at maximizing response. Is the day close to a holiday? What time exactly do you send them for maximum response?
- Coverage—As mentioned, when these certs go out you're going to get a lot of activity coming back in. Do you have team coverage for the inevitable questions you're going to get?
This is really a continuation of phase three. Certs have gone out, there's a lot of back and forth, and as people start completing their certs you start noticing who hasn't. Maybe it's the usual suspects. Maybe it's some surprise laggards. Maybe it's the new folk. Following are some potential motivators, whoever they are.
- Reminders—These are straight up email reminders. How often do you send them? At what point do the procrastinators just tune you out?
- Vary The Medium—There's more to messaging than email. Use your compliance software's dashboards. Use the company's internal television system. Make personal phone calls, even.
- Escalation—At what point do you copy managers? At what point do you suspend a dawdler's ability to execute trades?
- Good Software—Compliance software can make or break this follow-up phase of the cert process. Can you set automated reminders? Can you set automated escalation points?
- Fun And Games—Make it a competition. Consider doing a department-by-department completion scorecard. Offer some sort of prize to the winning team.
- Think Outside The Box—One enterprise financial firm was known to use its disaster recovery phone service, part of its business continuity plan, to robo-call procrastinators.
Congratulations. You've made it to the other side. Your internal due date has passed, though work remains. Some employees never did complete their certs, which puts the firm in SEC violation territory. Time for a final push, then some review, and then a look ahead to next time.
- Check And Check Again—Make sure you know who did and who didn't complete their certs. You started off verifying recipients. Now's the time to double check against that initial list.
- Review Results—Are there results you need to review? For certain answers? For specific items that needed to be addressed in certain certifications? Not all certs are created equal.
- Late Filers—The SEC is most concerned your firm has a cert policy in place and did everything it could to deal with late filers, including issue fines. Make sure you document everything.
- Thinking Ahead—What worked? What didn't? Did any of your messaging and/or motivators work better than others? Document any and all feedback and keep it handy for next time.
THE FINAL STEP
Compliance software can make all the difference in the certification process. Look for the ability to combine certs. Look for a full suite of customizable alerts, so you can set and forget reminders and escalation points. Look for the ability to build a single certification that can go out to multiple audiences, or the ability to design a cert that asks a series of complex questions. Look for a reporting suite with automatic result tracking, automatic report delivery, and graphical report and case-management capabilities.
Certs always present a certain level of challenge. You are dealing with people, after all. People who have their own inscrutable reasons for doing or not doing what they're tasked with. But a calculated and streamlined process, paired with the right kind of software, will go a long way toward making the whole endeavor more efficient and more bearable for everyone involved.