On May 28, 2020, FINRA issued its Regulatory Notice 20-16 sharing firms’ WFH practices observed to date. They include common practices adopted across most industries, as one would expect.
During the TRANSITION TO WFH, firm practices included:
- Increased Customer Assistance through outreach and web-based communications, to ensure customers knew how to access representatives and other resources;
- Location Monitoring & Contact Lists to know where staff were and ensure they knew how to stay in touch;
- Increased Support for staff, including more frequent training and communications, and increased tech support; and,
- Heightened Focus on Confidentiality and CyberSecurity issues, including reminders, training and monitoring of heightened risks.
WFH SUPERVISION efforts included:
- Increased Communications;
- More Frequent Meetings, with greater regularity;
- Increased Supervision, through supervisory checklists, remote affirmations, and encouragement to “over-escalate” issues to supervisors and management; and,
- Monitoring of Emerging Risks.
TRADING SUPERVISION included additional precautions attempting to replicate virtually various “line of sight” supervisory techniques, including:
- Pre-screens with reminders and affirmations;
- Surveillance through lowered reporting thresholds and increased scope of trade or exception reporting; and,
- New Monitoring Techniques, for example, always-on web-cams, frequent check-ins or roll-calls, and recording of real-time chat-rooms.
FINRA Reg. Notice 20-16 is here.
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