The Solutions system is built on the premise that many firms can get out of sync between their policies and what they actually do.  This is a risk we have often seen with our clients and in our experience as we sat at the actual desks in past firms.  The software implementation is designed to identify a firm’s procedures and put a workflow in place to enforce each one.  It manages a Compliance Calendar and Attestations, as well as Tracking and Evidencing of all of the processes.  It also manages what we call “ad hoc” requests – those requests that are not regularly scheduled (for example marketing and advertising or outside activity approvals).  It tracks all review and approval of these requests and provides logs of the approvals/rejections of such activities.

Yes, the system is fully Write Once Read Many (WORM) compliant and available for use as a Books and Records location. In fact, we encourage our clients to store as much of their documentation on the system as possible to keep all Compliance related information in one, easily searchable location. We teach clients tips and tricks to make searching and using the system for storage of records easy, so when an audit comes all of the items needed are right at their fingertips.

Yes, the system is housed on Amazon Web Services (AWS) but is also backed up regularly to secure network systems. We recommend clients use the web-based platform in order to easily receive the most up-to-date enhancements at no additional cost.  However, there is also an option for clients to house the system on their own network.

Yes, the system is mobile accessible. This allows our clients to use Workflows and approve activities while away from their computers, a feature we consider essential in today’s advancing technology landscape.

Yes. To get the most out of the Solutions system, every employee should have a login to the system. The software is designed to interact not only with Compliance but with all departments and all levels of a firm.

Oyster Solutions offers both an email address and a hotline for support issues. Most issues can be resolved by calling the hotline or sending an email. More complex issues may be escalated for additional review.

Oyster Solution is a joint venture between Oyster Consulting, LLC and Devyze, LLC, our technology partner. While many software systems are developed by a technology firm and compliance consultants are brought in to advise on the project, we took a different approach and designed a system based on user needs and experience.

Oyster Solutions you not only get a customizable software package able to handle your Compliance and other process and policy needs, but you also get the expertise that comes from working with experienced industry practitioners, people who have sat in your seat and understand your needs and concerns as well as the challenges you face every day.

Yes. We have clients who are happy to talk to you about their experience using the product and about the process of implementation.

Depending on the firm and the complexities of the workflows put in place, we generally say an implementation takes 6-8 weeks. Some of our implementations can take a longer or shorter amount of time, so we don’t like to put a number on a process we believe is unique to every client.

If a firm is new and does not have policies of their own to implement, the process includes drafting and customizing policies to fit the unique business model and processes of the firm. For many of our clients, though, they already have policies in place. It is our belief that they should continue to run their Compliance Program, not one we prescribe for them. In those cases, we review every word and evaluate the existing policies. We identify each task, no matter how small, required by the policies. We also identify questions that might include potential misstatements, possible omissions, or inconsistencies. All of these items are then reviewed with the firm. We offer clients a menu of existing workflows they can choose to put in place, or we can custom build workflows to suit their needs. For many of our clients, we then offer to conduct testing of their current procedures and issue their annual review report for the current year or return in the coming year.

Just like the Compliance Program of a firm, we believe training is a unique experience for each firm and no two firms thrive on the same experience. We customize our training approach for each firm. We offer web training, conference calls, written documentation and onsite training – whatever best suits the needs of the client. For most firms the Compliance Contact will participate in regular meetings with Solutions Staff until the entire Compliance Calendar has been run at least once. We find most calendars run on a quarterly cycle, with one or two Workflows that occur annually. So, we meet regularly during the first quarter after the system “launches” and walk through each Workflow manually before we allow them to launch automatically. This allows our clients to see the system in practice before they are off on their own. After that first quarter, they can always contact our Support Hotline for assistance with any questions or concerns.

Yes, the system has been used by firms as they have been through audits and has performed well under regulatory review. In fact, in our experience, an examiner being able to show an item on the calendar schedule can assist in eliminating a finding from the issue list, even if the procedure is not clearly spelled out in the procedures of the firm.

Our basic package includes the Planner and Govern modules, which house your Compliance Calendar, Policies and the Workflows to enforce these as well as any other customized Workflows your firm may wish to implement. As enhancements are added to these two features of the software, they are automatically incorporated if you use our web-based platform at no cost and can be periodically incorporated if you choose to house the software on your own network.

No. We may add optional features such as the CAT tool or Monitor platform. Enhancements made to the modules you subscribe to are included in your subscription. We do not ask that you pay for those updates.

Yes, our staff takes information security very seriously. In addition to a roles-based system allowing access to information within the software based only on how a firm sets up each individual user, we also offer additional security features such as single sign on and dual authentication. While it makes receiving updates to the system more challenging, firms can also choose to house the software on their own network systems if their security protocols require it.

The Monitor Platform is an add-on module that is currently in the testing phase. Monitor provides multiple applications that can be helpful for any firm:

1. An alert-based monitoring system for employee and client trading accounts that will flag unusual or “red flag” activity within an account for review at a supervisory level.
2. The ability to bring multiple platforms/custodians/business units (in this case multiple entities) together under one umbrella for management reporting and tracking of assets, transactions, and regulatory reporting.
3. A system that tracks not only brokerage licensing when needed, but also tracks insurance licensing across individuals and states (matching required licenses and continuing education requirements versus the fifty different states and their varying requirements). This functionality would be available across both insurance companies and states

The CAT Tool was designed to monitor and analyze trading data reported to the Consolidated Audit Trail (CAT) as required by FINRA.  The tool currently provides clients a centralized application to ingest CAT reports for multiple CAT Reporting Agents (CRAs).  These reports include the CAT submission file, the ingestion file and any applicable error file, providing clients a comprehensive view of their CAT reporting.  The analytics suite includes Equity and Option CAT reporting event breakdown and statistics as well as customizable reports and dashboard views.  The CAT tool will continue to be enhanced to comply with the regulatory phased-in approach outlined by FINRA and is currently under development to include error repair capabilities.