Episode 74: Supervision Considerations under the COVID – 19 Pandemic

On episode 74 of the CCO Buzz, our Senior Compliance Consultant discusses supervision considerations for the current COVID-19 Era and how firms can start planning for the future.


CCO Buzz: Hello and welcome back to the CCO Buzz. On behalf of Core Compliance, we hope you and yours are all safe and well during these uncertain times. On today’s episode we have Core Compliance’s Senior Compliance Consultant. He’s here to discuss supervision considerations for the current COVID-19 Era and how firms can start planning for the future. And with that, let’s begin…

During the COVID-19 Pandemic, are there supervisory considerations that firms should be thinking about?

Sr. Compliance Consultant: Yes.  Actually, there are numerous considerations that firms should be thinking about, but most importantly, firms should be proactively communicating with their employees reminding them of their responsibilities under the firm’s compliance program.

CCO Buzz: Interesting. I know for a fact that at Core Compliance we consider client communication, as well as communication as a team, a huge priority in the current landscape. In your opinion, what steps should firms be taking during this time to increase team and client communication?

Sr. Compliance Consultant: There are numerous things a team could implement to strengthen communication, but here are three that come top of mind:

  • I encourage firms to have regular weekly meetings. It is a great opportunity to pivot and grow. You should be asking all members of your team what is working and not working – and collectively figure out how to operationally overcome those hurdles.
  • I also encourage clients to proactively remind and communicate to their employees the importance in following their firm’s policies and procedures. During difficult times, like now, it is integral that employees do not deviate from their established policies and procedures or fail to adjust to new implementations, particularly regarding client communication. Your team must understand that a firm’s Policies and Procedures (“P&P”) are established to supervise and protect both them and their clients.
  • To ensure comprehension and understanding in regard to communication, I also strongly recommend that firms have their team complete compliance attestations. As firms navigate the changes and continue to implement new technologies and methods, we need to make sure that they understand and communicate any concerns regarding personal trading, outside business activities, use of personal devices, or any other new implementations.

CCO Buzz: Wow, those are some valuable insights for the current and constant evolution of compliance programs. In your opinion, are there other steps that firms should be taking?

Sr. Compliance Consultant: YesI urge firms to not let the uncertainty of the present hinder their established culture of compliance. It is imperative that firms continue to maintain and align with their regular compliance calendar, education, and overall programs. This includes personal trade pre-clearance, your annual training program, quarterly attestations, cybersecurity controls and cyber phishing exercises, to name just a few.

Additionally, now would be a perfect time to update your firm policies and procedures to address working from remote locations and other discrepancies that might incur risks.  As annual reviews are required for all firms, now would be a great time to complete and make the appropriate adjustments to your P&P manuals and controls, ensuring you have documented and made response to the pandemic’s operational hurdles.

CCO Buzz: You mentioned the importance of remote considerations during these times. Are there any specifics you could offer our listeners?

Sr. Compliance Consultant: Yes, first and foremost, employees should notify their managers if they are not feeling well, so work can be reassigned. Employee health is most important.

Also, everyone should be extra vigilant while working from home. Firms need to not only monitor, but also, they need to look for and question any suspicious emails as bad actors have increased their activity. This includes phishing, distribution of malware and malicious phone applications, and phishing through text messages.

Employees should also proactively communicate if they are having issues, whether they are system access issues, concerns about possible cyber threats or general questions about complying with firm policies. Following protocols for client confidentiality and privacy is essential during these times, as working on home networks or personal devices can add an additional layer of risk.

Lastly, and as a partner for our clients – Core Compliance is preparing them for the future. Firms should begin discussion and planning for what it will look like when their employees can go back to the office.

They should be asking – How will this affect their procedures?  What happens when you have remote workers and workers in the office?  Will some protocols or controls need to be changed?  This is a challenge that not many firms have begun to consider, but the Core Compliance team always pushes for collaborative and innovative solutions. We encourage our clients to take time to consider how you can bring your team back into the office both efficiently and safely.

CCO Buzz: Wow, James. That’s a lot of information to take in, but everything was a helpful starting point for the new horizon of the industry. Is there anything else you’d like to add today?

Sr. Compliance Consultant: Yes, one last thing. As Core Compliance is a constant partner of the industry, I will be a panelist on an upcoming NSCP webinar, entitled “Forward Thinking: New Focus Areas and How Compliance Programs Need to Change for 2020.” The webinar is scheduled for Tuesday, June 16th at 11 AM (PST)/ 2 PM (EST) and we will be covering additional considerations, like the ones we discussed today. You can register on our website or via NSCP.org.

Register for the Webinar Here

In the meantime, if you or your firm need any assistance or guidance navigating these uncertain times please do not hesitate to reach out to the team at Core Compliance. We are here to help, support and guide you to meet your compliance objectives. Feel free to contact us at www.corecls.com or call us at  (619 )278-0020.

As I tell all of my clients – we are in this together.

CCO Buzz: That’s a great sentiment to end on. And I can’t wait for that webinar! Thanks for joining us today.

Sr. Compliance Consultant: Thank you!

CCO Buzz: Well that’s it for this week’s episode. If you’d like additional information, please check out our website at www.corecls.com. You can also follow us on Facebook, LinkedIn, or Twitter @CoreCls. Thank you, and we hope you tune-in to next week’s episode of the CCO Buzz.



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