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Insights from one of the highlights of our US User Conference
At this year’s US User Conference, one of the highlights was Increasing Employee Engagement In Your Compliance Program. Moderated by Star's Director of Product Strategy, Tim Ward, this hour-long session was attended by compliance officers and STAR Platform users from across the country, all of whom offered actionable insights on issues that can bedevil even the most experienced compliance officer, along with a few cautionary tales worth taking note of.
ACCOUNTABILITY COUNTS
"Earlier we talked about accountability. About switching from the notion of 'this is what you have to do' to 'this is what you're accountable for.' All of us, as employees, are accountable for something. By changing how we approach compliance, as well as the terminology we use in our communications, we'll get better turnaround times when it comes to the simple things, like certifications, as well as better results overall."
"An initiative at our firm, which is very large, is to get greater accountability at the supervisory level and in upper management. To achieve this—to get folks from the middle of the organization to the top more engaged—we're trying to provide them with more data, which we believe will lead to them being better informed and hopefully more accountable overall. Accountability at every level is important."
SIZE MATTERS
"We're a small shop. Ensuring participation, in some respects, is easier for us because we can do one-on-one training with every employee on their first day. So I'll sit down with them, walk them through the system, and they can put a face to compliance right off the bat. And the implied threat always is, if you don't do what you're supposed to do, I can just show up at your desk. That said, we're trying to move away from handholding. We do a lot more with automation now."
"Out of 40,000 total employees, 12,000 are covered, but that number is going to go up. Education will be key, but at that scale it will be challenging. We believe making small changes to the compliance platform will be of immense help. Optimizing the user experience by optimizing the user interface. Grouping together particular functions. Being better about key words. Being able to deliver different types of communications within forms. Inserting little phrases that align with firm policies and procedures. Multiply that by 10,000 or 20,000 people and that can make a huge difference."
KNOW YOUR AUDIENCE
"You have to take more time with certain groups, with certain individuals, who've never had to think about compliance before. We have 18,000 employees that will eventually be on the STAR system. We're about halfway to that number, and are running into the most pushback from people who've been around a long time but have never had to be covered before. They'll say: 'I've been in marketing for 20 years. I don't even work accounts.' But the person on the investor side, who's been around forever, doesn't care."
TAILOR YOUR MESSAGE
"With people who aren't in active trading roles, their spouses won't necessarily understand why they have to be involved. So I'll occasionally get on the phone with a spouse and explain why our policies are the way they are. I feel like if I take the time to explain the approach, to explain what the regulation is, how it all works, I can get through. It's a high-touch, full-service operation for our compliance team."
"We want to retain our people. They know they can go to Google or Facebook without facing all these restrictions, these compliance requirements. So we have to work hard to explain why they need to comply. Why the firm needs to comply. One good argument we've found is: 'Our clients subject their employees to this, so why not us? It's only fair.' That seems to get through."
"Compliance isn't just about protecting the firm. It's also about protecting you, the individual employee. We're trying to protect you from even the appearance, the merest perception, of having done something wrong. If you always cross all your t's and dot all your i's, and someone near you gets into trouble with the SEC or FBI, we can say, and you can say, you did everything you were supposed to."
BE FLEXIBLE, BUT NOT TOO FLEXIBLE
"I'm not opposed to sending messages in red all-caps. I'm not opposed to being stern at times. The first message might be warm and fuzzy. I see myself as being a partner in the business, rather than being the guy who says no all the time. But for those people who are late, or are getting dangerously close to being late, that can be a good time for the red all-caps."
"I understand the whole kid gloves thing, that you want to have some deference to upper management. But it gets really dangerous if you go too far. How do you look a client in the eye and say we have tone at the top when we have different standards for the c-suite? So I've never acquiesced in that manner. And on something as simple as a cert? Where you're asking someone to log in four times a year? It's the most basic compliance requirement. It's a condition of employment. So I've been as stern with them as I have been with anyone else."
BE HELPFUL, BUT NOT TOO HELPFUL
"We [StarCompliance] had a client that was getting phenomenal response and completion rates. Really unbelievable performance. It turns out the firm's compliance team was doing EVERYTHING for the employees. So now, the client essentially has to do a second rollout. And they have to get the employees doing the work. They're practically starting from scratch. But the bar is set so high now. It's going to be difficult to reach it."
