
By Oyster Consulting LLC
Subscribe to our original industry insightsFINRA recently released a regulatory notice to help firms understand how their peers are responding to the COVID-19 outbreak. In this Regulatory Notice (Notice), the FINRA staff shared certain observations based on discussions with member firms about steps taken to transition personnel to a remote work environment. The observations were not offered as recommended practices but represented a compilation of information gathered that firms may find useful depending on their circumstances. In addition to addressing the transition of personnel to remote work environments, the Notice addresses challenges relating to remote supervision.
To help customers deal with office closures, firms have provided customers with back-up contact information and have redirected telephone lines.
Firm associates have been required to report their remote locations, allowing the maintenance of a record of the locations for all remote personnel. Contact information for assigned points of contact within various departments has been provided.
The Notice provides examples of information and tools to facilitate working remotely, including:
Additional guidance was provided to firm personnel regarding these topics. Associates were reminded of their obligations regarding the confidentiality of customer information and were instructed to maintain a private workspace and take extra precautions when working near family members or roommates while working from home. Associates were also advised of increased cybersecurity vulnerabilities and potential fraud risks.
Firms that were well-prepared to supervise associates in a new remote work environment identified the use of such things as supervisory checklists, surveillance tools, incident trackers, email review and trade exception reports. Some examples of additional measures that were taken to address remote supervisory challenges included:
Where necessary, firms implemented new trading tools that allowed access to trading systems and provided supervisors with enhanced remote supervision capabilities. Some examples of those capabilities included:
Some firms have implemented additional measures designed to help with supervision of customer communications. Included among them are:
Many firms stopped conducting on-site inspections and, instead, created and implemented a temporary, fully remote inspection plan using video conferencing, electronic document review and other technological tools. Depending on the duration and severity of the stay-at-home orders and travel restrictions, firms were planning to complete the onsite portions of the inspections in the future and, for high risk branches, to prioritize those inspections.
"*" indicates required fields
Download the Capital Markets Services eBook to learn about CAT Reporting, Trade and Position Reporting, Market Access and Best Execution.
Download