FINRA’s 2021 Report on Examination and Risk Monitoring found that with regards to Rule 2210, Communications with the Public, many firms had insufficient policies, supervision, and recordkeeping for their digital communications.
FINRA reminded firms that a “digital communication policy must address all permitted and prohibited digital communication channels and features available to your customers and associated persons.”
Our new Policies solution will help ensure that your registered advisors are utilizing your firm’s most current and up to date policies and WSPs with regards to Communications with the Public. Advisors can even designate these Rule 2210 specific WSPs as “favorites” for quick and easy reference within the Policies app.
FINRA also reminded firms about the need to provide training on relevant FINRA rules and firm policies when it comes to communications with the public. With our Policies app you can send links to your advisors when new policies are published. Each policy will state when it was published and by whom. You can even link within your policies to specific related FINRA regulations and rules.
FINRA cited as some of their concerns: “Not maintaining policies and procedures to reasonably identify and respond to red flags—such as customer complaints, representatives’ email, OBA reviews or advertising reviews—that registered representatives used impermissible business-related digital communications methods, including texting, messaging, social media, collaboration apps or “electronic sales seminars...”
SiteQuest Compliance has several applications to support compliance personnel in their efforts to supervise “Communication with the Public”.
Our Eagle Eye app will assist you in monitoring the internet while discovering any potential undisclosed OBAs, social media accounts, blogs, websites, and more. With built in automated documentation you will have everything you need including when a result was found, who reviewed it, comments that were made, and timestamps on every action taken. From a regulatory point of view, with Eagle Eye you will have the full story of what communication content looked like at the time of review, giving you everything you need to respond to a regulator.
Eagle Eye's “Heightened Supervision Mode” empowers you to monitor your advisors at a variety of levels. For those that push the envelope a Heightened Level of Supervision may be required. In any situation, Eagle Eye allows you to customize your approach with built in automation to notify specific individuals up the chain of command.
FINRA stressed the importance of notification and monitoring. “Requiring registered representatives to notify compliance of any changes to approved communications, and conducting periodic, at least annual, monitoring and review of previously approved communications for changes and updates.”
With our SQWatcher application, firms can monitor communications on websites by actively supervising for unapproved changes and providing historical archives of the sites. SQWatcher can even monitor websites hosted by non-approved website providers.
SiteQuest Compliance supports your firm’s adherence to regulatory requirements 2210 by actively supervising the internet, monitoring and archiving websites, and ensuring that your advisors have access and are utilizing the most current policies and WSPs with regards to Communications with the Public.
With our suite of compliance applications SiteQuest Compliance has become a trusted partner for over a decade. Contact us today and see for yourself how our suite of applications will work for you.
Isn’t the whole point of a vacation not to work? Why would you have to make a plan not to work?
According to a recent Harris Poll 66% of Americans report working when they take PTO or vacation days. 42% admit to contacting a colleague while on their holiday.
Many of us simply cannot unplug from work. Whether self-imposed or an unwritten rule of your workplace, employees are not taking the vacation time they need and deserve.
That’s why we’ve put together 5 tips on how to ensure your summer vacation is as enjoyable and work-free as possible.
1. First, make a real commitment to actually taking a vacation.
Going through the motions of buying airplane tickets, hotel reservations, and drawing up a basic itinerary doesn’t count. Just because you’ve made plans to not be physically present in the office doesn’t mean you are not mentally and psychologically still wrapped up in your work.
The whole point of paid time off is to rejuvenate and recover. You simply can’t be your professional best if you don’t take time off. So get into the mindset and buy into the fact that your holiday is supposed to be time away bringing you back to the workplace as a better, more refreshed person.
2. Ditch the guilt.
You can’t relax if you’re worried about what you’re “not” doing. However, it’s easier said than done for some of us to not feel guilty about taking time off. Do what you need to do in order to minimize feelings of guilt. For some of us that may mean rescheduling a vacation to a better time (e.g. not in the middle of a new product launch) or trying to cram in your tasks before you leave. For others, that may simply mean taking a colleague out to lunch to thank them for covering for you ahead of time, or sending them a treat when you come back.
3. Communicate with your colleagues and managers early on about your absence, and don’t just block the time on your calendar.
Be sure to send calendar notifications to those you think really need to have this planned into their own work schedule because they will have to cover for you or simply need to be aware. Everyone is busy and it’s hard for people to be aware of anyone else’s schedule. Many of your colleagues want to respect your time off but simply don’t remember or don’t realize that you will be gone.
4. Create an “Out of the Office” auto-reply for your email and your work voicemail.
Auto-replies work. Customers and co-workers will understand that you will not respond till you are back from your vacation. They just need a reminder that you are away.
In some cases, your boss will be the one that needs a reminder, or it may be your major clients or regular contacts. In other cases, it’s simply telling the team-members who will be covering for you to be proactive in cc:ing you (or not, if you prefer) but not expecting you to respond. Doing this may not reduce the number of emails or voicemails you return to, but it will set expectations and explain why you are not responding for a while.
5. Minimize your “other” work on vacation.
Your job responsibilities are not the only kind of work that you should try to minimize on vacation. For many women, care-taking responsibilities surge to the forefront on vacation. Just ask any mother and she will tell you that childcare and family responsibilities on vacation can be so exhausting that it’s more restful to actually return to work. Making a plan to enlist babysitters on vacation, family members, or partners for their support while you're taking time off is something many individuals neglect to do.
If you’re like most full-time employed Americans, you work hard. According to a Gallup poll, adults employed full-time work reported working an average of 47 hours per week. You deserve a vacation and they don’t just “happen” without some active thought and planning.
For many in the supervision and compliance departments they feel like their jobs are never ending. That is why we have built in automations for our applications.
Eagle Eye is always running in the background. You can customize alerts so that if you are out of the office alerts can go to another designated person.
From a regulatory point of view, Eagle Eye will give you the full story of what content looked like at the time of review, even if you are out of the office, giving you everything you need to respond to a regulator.
SQWatcher will continue to monitor websites, even when you are on vacation. With our easy to use workflows you will be able to go through any changes that occurred while you were away.
Our easy to use workflow feature sets SQWatcher apart from the competition. Reviewers can identify what has changed on the website, where changes occurred, and when the changes happened. Our content ignore feature gives you the ability to ignore sections of the site that generate unnecessary reviews like stock tickers, date widgets, and more. Saving you countless hours.
It’s just the beginning of June so if you haven’t had the chance to sit down and really plan your summer holiday yet, make sure your vacation plans incorporate these ideas.
Then give us a call and let us show you how our applications will help streamline your processes and ease the burden of piling up workloads after your PTO.
About James Cella
James Cella is the President of a growing and innovative compliance technology provider called SiteQuest Compliance. James is a customer-centric individual and focuses on building and sustaining positive and lasting relationship with his clients and partners. James and his family are "super fans" of University of Utah Football and have attended nearly every home game since 2002. Go Utes!