Communications with public and institutional clients are required to be retained (SEC Rule 17a-4, FINRA 2210), however, meeting tools such as Microsoft’s Skype for Business, Cisco’s WebEx and Citrix’s GoToMeeting have different and somewhat difficult capture methods. The following describes 17a-4’s guidance as to ‘best practices’ to capture this content and archive in accordance with industry regulations.
6/25/15 – Millbrook, NY – Registered Representatives and Financial Advisers appreciate the efficiency of providing financial analysis and investment information using on-line meeting technologies. However, such communications are regulated by the SEC (Rule 17a-4) and FINRA (Rule 2210) and require capture, supervision and retention. 17a-4 offers recommendations for managing these types of regulated data sources.
As with many technologies, on-line meetings were not designed with compliance in mind and offer some very significant compliance challenges, including:
- The capture of an on-line meeting is often in a video format which cannot capture or scan for textual content;
- The capture requires the presenter to click on a record icon. If not clicked, then the session is not recorded;
- These meetings are not pushed through the normal communication capture mechanisms such as an email server or SharePoint library.
Microsoft’s new Skype for Business (formerly Lync) requires the presenter to:
- Before beginning, click on ‘More Options’ then ‘Start Recording’
- Upon completion, click on ‘More Options’ then ‘Stop Recording’
- Wait for the recording to be captured on the presenter’s PC. Once complete, the presenter may publish the presentation and save to a SharePoint folder
- The recording may then be captured on SharePoint and written out to an archive or otherwise backed-up in accordance with retention regulations.
For Cisco WebEx sessions, users can save recorded sessions onto the Cisco site where compliance can download and archive.
For financial institutions wishing to allow their consultants to leverage on-line meeting technologies, 17a-4 provides various types of consulting arrangements including an On-line Meeting Compliance Review which will document the capture processes and controls for retention and supervision.