(Blog 2 of 2)
There are four main areas of regulatory client outreach that easily lends to being automated:
1. Client List Generation for In-Scope Clients
In determining the clients who are in-scope for the impending regulations, it is important to remove as much of the interpretation of regulatory rules from this process and generate a list of clients based on a defined criterion. By incorporating a regulatory rules engine into this process, in-scope clients can be easily identified based on a combination of data including the client type and role, products, jurisdiction, booking entity, revenue etc. The rules engine should also be capable of determining the data and documentation already held in-house (depending on integration with other solutions / repositories) and the outstanding information that needs to be collected afresh.
A significant part of the client list generation will involve understanding the client population, with a view to prioritizing the clients to be contacted and focusing resources to ensure outreach and education to the right clients.
2. Automate Client Segmentation, Email Integration, Correspondence & Outreach
An automated client outreach process should enable financial institutions to group clients by ‘outreach type’ in terms of messages that need to be sent to each and the methods of communications appropriate to each client group e.g. phone, letter, email etc.
As part of this process, the solution should also have correspondence HTML and Word document templates that can either be uploaded or made available through the solution itself (both for bulk and ad-hoc processes). Mail server integration is key to achieving these efficiencies.
In addition to generating emails and bulk mails, the solution should also be able to generate a file for 3rd party postal delivery companies. The ability to do all of this in-application will eliminate the need to save different versions of documents in other repositories and enhance ‘shareability’ of the content
3. Automate Incoming Responses, Processing, Tracking & Reporting
This stage involves the greatest operational challenge posed by Regulatory Outreach Programs and potentially the most opportunity to generate efficiencies by rethinking the process.
The ability to send correspondence, while manual, is usually simple enough. However, it is far more difficult to ensure high response rates and receive and process new information, keep track of it, provide updates, reminders and report on overall effectiveness – especially if this remains a manual process. By automating this part of the client outreach program, financial institutions should be capable of realizing the biggest benefits of all – time savings, meeting of compliance deadlines and actionability.
- The first step involves the submission of information by clients. There are simple tools that can be put in place to make this a less cumbersome process. For example, the ability to securely email data and documentation or update/upload via a client portal will save a lot of valuable time and hassle.
- When information is submitted by clients, it should be automatically processed (with an option for a four-eye review for high priority cases or sample testing) and tracked accordingly, providing the Client Outreach Team with a matrix of information that has been received and those that remain outstanding. This will enable the team to quickly evaluate non-responsive clients and manage reminders on an ongoing basis.
- The information submitted, particularly if material changes have been detected which may affect compliance or risk scoring for other regulatory measures, should be capable of being escalated quickly to compliance, legal or sales. The ability to integrate the Client Outreach Module to the core client lifecycle, compliance or onboarding solution will be critical to enable this to happen. Furthermore, by providing a small number of dashboards for each team, updates and reporting can be done in real-time without the need to use an external email program.
- To enhance management information reporting, the solution should incorporate MIS functionality that will show progression and productivity of the client outreach program. Key metrics will include:
- High-level statistics on volumes at each stage of the process
- Progress statistics by business area and region
- Resource profiling and projections.
4. Client Data Remediation
While the primary objective of a regulatory client outreach program is to collect the data and documentation needed to evidence the compliance process, a secondary objective will always involve client data remediation. As a result, the client outreach solution should incorporate workflow cases to enable data cleansing and identification of invalid email addresses, and update these attributes accordingly in the main client data repository.
I can’t imagine that any financial institution relishes the thought of putting into place and managing a manual client outreach program. With the number of regulations sure to come down the tracks in 2017 and beyond, automating the Regulatory Client Outreach process is a no-brainer. In addition to improving internal operational efficiencies, it promises to help financial institutions achieve compliance ahead of regulatory deadlines, improve auditability and enhance client relationships.
Given the regulatory roadmap for the next few years, there will be plenty of opportunities for Regulatory Client Outreach to become business as usual. With the right approach and the right investment, financial institutions can transform this sizeable operational challenge into an efficient, effective and positive process.