"The regulators aren't asking that you have the best performance or be the smartest firm in the world, they're asking you to self-actualize and be the best you can be from a compliance standpoint."
— Jeff Cowley, Chief Technology Officer, InvestEdge
Jeff is a wealth management technology executive at InvestEdge, with 20 years of experience in the financial services industry working closely with HNW & UHNW investment management institutions. Leveraging technology expertise and in-depth knowledge of the investment management process, he provides solutions that address his clients’ critical business issue.
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This episode of Wealth Management Today is brought to you by Ezra Group Consulting. If your firm is evaluating new technology or looking to improve your current wealth platform, you need to contact Ezra Group. Don’t spend another day using technology that doesn’t offer an elegant user experience. Your advisors and clients deserve better and you can deliver it to them with the help of Ezra Group.
Topics Covered in this Episode
- Current trends in the compliance business around centralization of activity, outsourcing, and business segmentation [03:48]
- How companies can make sure they maintain standards and are able to answer to regulators when outsourcing more of their compliance [05:50]
- Discussion about quality control or other concepts that they can be brought in from other industries to manage the data being generated and ensure that the information being logged is accurate [09:07]
- Adoption rates of Regulation 9 processes, and how that affects other divisions [13:08]
- The rate of false-positives regarding erroneous triggers [18:37]
- Jeff's best practices around regulation and oversight processes, and how firms can improve the way they're handling these processes and procedures [24:22]
- How compliance governance structures are becoming the overall governance structures due to merging investment management with compliance [30:44]
- Does the OCC have the bandwidth to handle the oversight they have taken on? [34:29]
- Discussion around the reasoning for the drastic increase in fines over the last year [38:35]
If you are interested in more information about some of the topics Jeff and I discussed, these blog posts would be useful:
- InvestEdge Peers a Decade Into the Future at Their Strategic Partner Forum
- 19 Ideas from the T3 Advisor Conference That Your Boss Needs to Know
Complete Episode Transcript:
Craig: And welcome to the World of Wealthtech. This is your host, Craig Iskowitz. I am a consultant in wealth management and I run a consulting firm that helps banks, broker-dealers, asset managers, RIA's, and fintech firms with technology strategy decisions. This is my podcast where I try to present information to help the industry deep-dive into different areas of wealthtech, wealth management, and basically talk about stuff that I find interesting and I hope you do too.
Craig: Welcome to another episode of Wealth Management Today. On the podcast I'm excited to have Jeff Cowley, Chief Technology Officer at InvestEdge.
Jeff: Thank you for having me.
Craig: While some people think compliance is boring, people who have been fined or have gone through audits know it's not a boring topic at all and it's something everyone needs to be focused on, so I'm really happy you're here to talk about it. We've done some work together and we've been in the industry a long time and I've seen you guys build a lot of terrific compliance solutions, so I thought it'd be great to talk to you. You've got over a hundred bank trust clients and you do a lot of compliance work, so what are some of the trends that you're seeing in the compliance business around centralization of activity or outsourcing or business segmentation?
Jeff: A couple of the things that our customers are starting to look at is how can they efficiently manage the process, right? What's their way of meeting their regulatory needs, and then also their corporate risks needs? As fiduciaries they're offering investment management services to their customers, and as part of that they have to make sure that their business practices and their processes and procedures around investment management are aligned to what they're selling to their customer. Some of the trends that we're starting to see out there is, probably 10 years ago the front office folks, the investment advisors, the relationship person, the portfolio manager, the trust administrator, those people were the people that were responsible for the compliance activity, right? They were making sure that they were adhering to what we call in on the bank trust side of the Office of the Comptroller of the Currency (OCC) Reg 9 investment and administrative review process. We're starting to see that now being handled by specific and specialized teams at the firm, trying to take some of that compliance work off of the front office and move it to the middle office or to the back office itself. One other thing that we're starting to see is firms are looking at ways that they might be able to outsource this activity. So maybe there is the ability to hire consultants to handle a piece of this or to outsource the work. We're piloting with a very large bank, and they're actually using offshore resources in India to address some of the tasks and some of the items that need to be addressed as part of their administrative review process.
Craig: So when they're outsourcing more of their compliance, how do they make sure that they maintain standards they need to be able to answer to regulators?
Jeff: The first thing that the regulators are concerned with is process and documentation. So our customers will typically have a Chief Compliance Officer or compliance committee, and they'll define all of those processes and procedures and they'll document those procedures. That's the first step of the process here. The story you always hear is, when the NCAA comes down hard on a firm, a lot of times for some type of nefarious activity around student athletes, they'll talk about institutional control. So the first key concept for our customers (people that are in the investment management industry that consider themselves fiduciaries) is they have to be able to document all of their process and procedures – that's step number one. The second part of that is they need technology and they need workflows in order to support that documentation and those process and the procedures, and that's where our technology comes in. They're able to configure their rules, their procedures, their tasks; they're able to configure that all within our technology platform there. So by defining the rules, writing them down, having standard workflows, being able to configure that into technology, that enables them to take pieces of that work.
Jeff: And one of the unique things about compliance is it's not too different from giving investment advice, right? It's a service-level activity that requires a lot of individuals to do a task or perform some level of work. And that task may be call the customer, check on a legal document, make sure you've checked about your investment policy with the customer, right? Or it may just say, check all the holdings that the customer has. All of these things, we look at them as an individual piece of work that a provider at a service firm needs to do. So by defining all of that, they can ring fence off activities and work that tends to be repetitive and low risk, and they can look at it and outsource that to an outside firm, just in the same way that technology firms outsource development; they have a framework and a structure, and they go to an outsourcer and say, we need to hire somebody that's going to do this task over and over again. And that's exactly how they're looking at this from a compliance standpoint, is they're outsourcing that task and that activity, but the firm has defined that task and that activity specific to them. And then of course it comes around auditing, logging all that information, all that is part and parcel to ensuring that adheres to the firm's regulatory and their business standards.
Craig: It sounds like there is a lot of data being generated. What kind of quality control or are there any other concepts that they can bring from other industries to manage this, to make sure that what they're logging is accurate?
Jeff: Yeah, there's a couple of key pieces. First of all, you have to have all the investment management activity; all of the positions, transactions, everything that's involved with managing a customer's account and providing investment management services for a fee. So you have all of that data that has to come in from the custodian or from their primary books of records system. So gathering all of that information, because a lot of times when a task is being performed it's typically around transactions or holdings. It's also around things like documents, information about the customer, have they had their statements set up, has somebody had a conversation with them, is the account funded? Those are all additional data points that don't come from the custodian, that are key in managing the investment management accounts themselves.
Jeff: So you start with the custody data, then you layer on what I'll call the metadata around the investment management process, and the last piece of this is all the data around the workflow, the task, and the activities. Who's working on it, when did they work on it, what were their comments on it, was there an issue with it, is there an exception to the work, do they have to escalate the work? All of those things are sort of that third layer, so if you think about that in the old Maslow hierarchy of needs, the base is the custody data, the second level is that investment metadata, and then the third level of this is that all of the data associated with the workflow and the communication between all of the people at a firm, and supporting all of that. And all of that data really makes up compliance data around the investment management process; controlling that, seeing it, visualizing it, using it for workflow, that's all key to ensuring that the quality and the defined processes and procedures that a firm has implemented, all of that data is required in order to make that happen as well.
Craig: So the Maslow hierarchy of needs, so the top level of compliance is self-actualization?
Jeff: Couldn't have said it better myself. It's really about being the best firm you can be, and when you look at what the regulators ask, that's what they're asking. They're not asking that you have the best performance or that you're the smartest firm in the world or that you have all of these things, they're asking you to self-actualize and be the best you can be, from a servicing standpoint. So flowing through that data you get to that point, and hopefully through best practices, policies, procedures, the right data, the right technology, the right rules, and the right workflow, we can enable our customers to self-actualize and realize the best investment management business that they can do. And again, I think that's what a fiduciary does, right? That's what I'm doing, the best thing for my customers. It doesn't mean being right all the time, it just means doing the best you can do.
Craig: Right. I think we just found a potential title for this podcast, "self-actualization of compliance."
Jeff: There you go.
Craig: Well, we might find more, we have a lot more to talk about. One thing I find interesting is the adoption rate of Reg 9 processes. It's a huge trend in the industry where you're seeing mergers or acquisitions where you have bank trust buying broker-dealers and RIA's now merging and they've got to go to the highest or the lowest standard, whichever you prefer. And Reg 9 is the highest standard, so they're pushing that out across all of their other divisions which didn't normally have that. Is that something you're seeing, and how does that impact those other parts and divisions?
Jeff: Yeah, that's absolutely something we're seeing. A lot of our customers have had a traditional bank trust or what I'll call high net worth or ultra-high net worth, some people call it a family office. They've gone out and acquired RIA's, whether those RIA's have been asset managers or they've been other wealth management firms where they may be managing family assets or they have a specialty in a particular area. And then the larger firms that also have a broker-dealer offering where they're offering fee-based managed account services, the regulators that come in and do the examination on the bank are going to look for the highest standard. And what they found is it goes back to that institutional control; do they have control over all the investment management services that are being provided to the customer, regardless of their registration? They're looking to go to that highest standard, and what they found is that the review process and the process that the regulators on the OCC or bank side of this have done around the asset management per se, there's a high level of scrutiny around that. And so we're seeing our customers that have those situation starting to look at this and adopt the investment review process. Because really it's not just an investment review process, it's an investment management process.
Jeff: And they're making sure, regardless of if they have to do a particular FINRA rule check or they have to disclose something on their form ADV as part of their RIA registration, they have to make sure that there's institutional control over what's happening in the accounts every day. Are we adhering to the asset allocation we sat down with our customer? Do we hold the right holdings, whether it's a share class or junk bonds; whatever it is, all of those things are now being looked at in a broader sense here. And by consolidating that investment management process across those three sorts of divisions, it may be a little bit onerous in the beginning but they'll have an overall reduction of costs. Because what it enables them to do is then move down to a single governance structure, right? They'll have a single risk structure, so they may have a Chief Risk Officer.
Jeff: So now the risk officer's not getting a separate committee oversight document from the broker-dealer side of the business versus the RIA versus the bank trust or the wealth side of it, they're getting a unified view of that. And as compliance becomes more and more part and parcel to all of the investment management business and being a fiduciary in that, it's probably less expensive to implement the OCC investment review process, which seems to have a high level of stringent rules in there. It's cheaper to implement it across all those levels and then basically unify all of your governance and your committee levels. Because those governments and committee levels, those are all high-level executives. A compliance committee at a large financial institution or a large bank that has multiple things, you have some pretty heavy hitters in there as far as the type of folks, the salaries, the amount of time that they're spending on it. They're all on the hook; nobody wants to get fined by the regulators. Whether it's the FCC, the OCC, nobody wants to get dinged on the regulators. So that implementation of a unified compliance process around the investment management business we're seeing as a heavy trend
Craig: That would seem to be something that you'd want anyway. Who wants to be managing multiple reports from multiple different divisions? It becomes confusing because the number of reports are multiplying,
Jeff: Absolutely. The more branches you have on that compliance tree, the more chances you have for getting dinged for not having that institutional control over the business. So solidifying that down to a single trunk and then making sure that all of this feeds up into the higher branches in an efficient manner is a key piece of that. You can look at the fines that FINRA and the SEC and the OCC have levied on firms over the last two or three years, a lot of it has to do with that control and the communication of information along the way, all the way from the operational folks up to the executive level.
Craig: So with all these reports coming in and all of this data, is there a high number of false positives where things are being triggered when you shouldn't be? Or is that not really a problem?
Jeff: No, that's a real big problem. If you're a large firm and across your wealth management division you have 50,000-100,000 accounts, it has to be done management by exception. You need to be able to implement your specific rules in the rules engine, and they have to be very precise so that you don't have those false positives. You have to narrow down the rules in the rules engine to identify where the risk is at, and then through that proper identification it really brings to light where those sort of problem children exist, and you can focus on that. And a lot of times the regulators will come in and they're happy to see that. Because they know nobody has a perfect business; that's not what they're looking for. They're not looking for perfection, they're looking for firms that have instituted a management by exception process that brings to light risk areas. And again, that risk can be a holding risk, it could be a trading risk, all sorts of different things. When they have systems that enable them to do that and then they have a process and the procedure, right? So in our system we have rules, we call them alerts, and these alerts create triggers, and those triggers are defined by the firm.
Jeff: So, for example, they may have a rule that says if it's a fund or an ETF, our concentration percentage is 6 or 7% within the account, but if it's an individual stock or an individual bond, they may set a concentration level down to 3 or 5%. And then they may dictate what type of stocks, so if it's a small cap stock maybe it can't be more than 2 or 3%. So the ability to configure your rules and your rules engine the proper way, and then ensure that when that alert happens that there's a process in place for the advisor or a centralized team to look at it and address it. That entire process has to be identified, documented, stored, and logged in a system somewhere, and that's really what our system does.
Jeff: And then there's aging; if it goes past 45 days and there's an issue, the firm (whether it's the Chief Investment Officer or a committee) have to know that this exception that was generated 40 days ago still hasn't been addressed. So they have to have a way for it to alert the user and say somebody has to take action on it. And again, it's all of that communication about what this issue is, how is it being addressed, making sure there's institutional oversight on the entire process, and then the entire process is documented. That's a pretty lengthy process. If you had to do that across every holding, it would take you a significantly large amount of time. That's why management by exception or rule by exception is critical in order for these firms to keep their sanity and really identify the risk areas.
Craig: You have to, you can't possibly do this all manually.
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Craig: With all this talk about oversight and regulation and data and all of the experience you've had being at InvestEdge almost 20 years now, I mean you've seen it all. Can you share best practices around bank trust regulation, oversight, process – how can firms improve the way they're doing this?
Jeff: A lot of our customers right now are in the middle of transforming; really what they're in the middle of is assimilating their regulatory process with their standard investment process. So I think that's probably the first part of this, is how do I merge our regulatory with how we're also checking and merging that into how we're managing our business every day. And the firms that are doing that, they're finding they're reducing boosts. So for example, account onboarding; that's a very intensive process with a significant amount of risk around it. So how are they merging their account onboarding process with their investment process? In our system that's called the initial review, and it's really a blend of the account onboarding process, there's custodial things there has to be done, there's legal documentation, there's a lot of check the box stuff that has to be done that's merged now into their compliance process.
Jeff: So they're adhering that the investment process and the compliance process are really the same, and through that merging they're achieving better risk results and they're also reducing their workflows. They don't have an account onboarding process and an initial review process and have them separated, they're now the same process. And the same resources that step through the account onboarding process are the ones that step through the initial review process, so that really is checking the box in two areas. Another area that they're looking at is how are they engaging the customer? What's the ongoing customer engagement? In the OCC there's guidelines in there that say you need to be at least reaching out to your customer once a year, and it has to be documented. And engagement is not just the advisor or the rep out in the field picking up the phone and talking to their customer; it's sending that quarterly performance report, or it may be accessed through a client portal, it may be sending a piece of information out to the customer via the client portal. Those are all customer engagements right there, and the more that you bring those in and you can join those processes into your regulatory process and you're showing the regulators that you're doing that, the key to that is you're showing them you have an established process. You're showing them that you're not just managing a bunch of customer accounts for fees and implementing investment advice; you are now really managing your entire engagement with the customer, and you've assimilated that with the overall regulatory processes and your business processes and your business risks.
Jeff: So that's really that merging of not making your regulatory process this outside process, but merging it in and then showing that to the regulators. Again, that goes back to that institutional level of control. If the regulators come in, you have to be able to easily tell them everything that's happening in your investment management book of business. What are your exceptions, where are your policies being violated, how do you have customers that are out of their tactical asset allocation? You've got to be able to show them that instantaneously, you can't run a bunch of reports and say we're going to get back to you in two or three weeks. So that entire process is a daily process. And then once you have that daily process and you have that insight, then you have to have an oversight process, and that oversight process includes governance structure. Who's overseeing everything that's happening? How are we communicating to the people out in the field, the front office folks? Who's overseeing those people and making sure the work that they're supposed to complete is being done? And then how does that go to the compliance committee, and then how does it go from the compliance committee or to the risk committee or to the executive committee? So how that process then folds into the governance structure is really important. And again, to do all of this manually or by spreadsheets or by Word documents, to be able to gather all of that and give a picture of what's happening in the firm and then how your oversight is, you really need technology to help the firms do that. That's probably the best practices.
Jeff: And then I think what we're starting to see, and you referred to it earlier Craig, is we're looking and seeing a lot of that blocking and tackling day in and day out that maybe was the responsibility of the front office advisor or rep. That blocking and tackling now is going to a centralized team, and they're not putting that onus on the advisors because they want the advisors communicating to the customers, talking to them about products, producing, and building those relationships; that's critical stuff that they want to continue to have happen, so they're taking a lot of that heavy-duty compliance and those compliance activities and putting it into a middle or a back office model, but all the time the front office people have to have insight. So the technology needs to let the front office people know that they may not be checking in on a legal document or looking at a bond that doesn't have a current bond rating right now, has a bond rating of NR to make sure it's not a junk bond. They may not be doing that activity, but they need the oversight to understand so that if something does pop up, they know how to handle it, or they can escalate that to their manager.
Craig: So these compliance governance structures are really becoming the overall governance structures, not just compliance anymore. Because you're merging investment management with compliance.
Jeff: Absolutely. Even at the smaller firms, the concept of risk and compliance is a key component of the entire executive governance structure. What we see for our larger institutions and even our smaller institutions now is on the investment side, they'll have a centralized oversight committee that will be responsible for reviewing all of the alerts or tasks, and they'll validate that the work is up to the standards of the firm. With our latest release we just implemented a concept of quality control that we sort of took from the manufacturing process here. They randomly sample work to make sure that that work is to the standard that the firm has set and established, and also to the regulatory standards. So that centralized oversight committee does all of that secondary checking.
Jeff: 10 or 15 years ago Craig, a lot of times that was the onus of a manager of the advisors, or in our world the managers the trust administrative officer, right? Now because compliance and risk is such a key component and the Chief Risk Officer is sitting at the executive level, just like the Chief Operating Officer at most of these financial firms. They're putting that committee in place to make sure that the standards that the firms have established exists, and then those people are also responsible to make sure that they're implementing best practices, are the people that are assigned the work the right people to do the work? All of that becomes this workflow management, and if you think about it in the context of manufacturing, providing investment advice to end customers and investors is no different than a manufacturing process, right? Except in a manufacturing process it's actually a tangible widget that goes from each workstation, and everybody does their part. If you think about this like a car, the first part of this is somebody puts the chassis together, then somebody puts the tires on, then somebody puts the steering column on, and somebody puts the engine in, and that's how a car is made.
Jeff: Well the delivery of investment advice to an end investor is really no different. Some person initially sets up and sells the customer, gathers information and demographics about the customer, puts that into their CRM system. Then they mark it to that potential customer, and then they onboard that customer. Then another person helps implement investment advice, and then another person sits down with the customer. Then another person implements trades for the customer, and then another person reviews the compliance and making sure everything's done, and another person generates a quarterly performance report. All of that is a manufactured process, it just happens to be a recurring process that happens all the time. That compliance and governance structure is really a manifestation of all of that activity, and making sure that all of that workflow is happening in the proper way, and ensuring that there's oversight to that.
Craig: With the OCC now getting involved with more companies.. I mean how many institutions is the OCC regulating, and is that going to be a problem where they're going to get bogged down with too many companies to oversee?
Jeff: I think that's always the challenge with government, right? So right now the OCC regulates about 1,300 financial firms right now, and that represents about 12 trillion in assets. Those 12 trillion in assets aren't all investment management assets; it's basically any cash or asset that runs through the bank is being regulated by the firm and the OCC. They have annual bank reviews, and actually they're moving into a process for healthy institutions where they're moving to an 18-month review cycle, where they'll come in and do an assessment. So if you have a good track record of process and procedures, you may be able to keep the OCC not coming every year, but every 18 months instead. That's something that just came about and they're talking about that.
Jeff: The other thing that's really interesting is that they are opening up bank charters to fintech companies, this is something that's just come down the pipe. That's really interesting in a sense that it's always been depository companies, trust companies, savings and loans, and banks, right? That's who they were focused on. Then there used to be an OTCS, an office of thrift and supervisory. And I think OTCS used to do savings and loans back in the day, but they were folded under the OCC a while back. I don't remember when, but they used to be the OTS and the OCC. Now they're offering fintech companies the ability to get regulated nationally by the OCC. So this is something new and an interesting turn of events, and clearly the OCC feels like they have the capacity to do this.
Jeff: This is another regulatory channel for a firm that says, maybe I want to implement robo advice to all of my customers. And I'm not a bank, I don't want to be in the retail banking business, I just want to take checks in for our customers and bring those checks in and offer them investment advice, and I don't want to go state by state to do this. So now they have opened an opportunity to offer bank charters to these fintech companies. And there's a lot of constraints, I'm clearly not the subject matter expert on this so if anybody should take a look at some of the recent articles, there was a good one on Harvard Law Review about this, and adhere to your attorney's and your compliance people. But it's an interesting turn in a sense that if you're a little RIA, you have to go and establish all of the (depending on what state you started in) state-level regulation. And if you're looking to move from state to state, every time you do that there's a cost associated with it. This way, if you look at the OCC and what they're doing, they're offering you a way to give you a national regulatory agent. So it's interesting perspective to see what the impact on RIA's and the broker-dealers will be on this, I don't really know. But I think you brought up a good point, is do they have the capacity to do this? One thing that they do is collect a lot of fines, so money doesn't tend to be an issue for them.
Craig: I was going to ask you about that, the fines went up from $40-$50 million to $750 million last year. What's caused that?
Jeff: From my observation, and clearly I'm not an attorney and I'm not the subject matter expert on this, but a lot of this goes back to that concept of institutional control. Do you have oversight of your business every day? Can you understand where you have weaknesses and risk in your business? And no business, no financial firm, no bank, no technology company, nobody operates in a risk-free environment. The biggest theme that comes from the regulators here is, do you have oversight, do you have control, is there an action plan, and do you have the policies and procedures to make sure that you understand that?
Jeff: And then, back to that governance structure again. Can the information go from the operational folks all the way up to the executive levels, so people know where exactly their risk exists? Specifically in our world, that is around the investment management side of the business here. So that big increase in fines tends to be more around, if you look at the trends, tends to be more around institutional control than a specific violation of a particular rule. Violations of capital requirements, those types of things on the banking side of this, those are all very much balanced sheets driven, and those do make up a portion of this. But after the 2008 downturn in the market and all of the changes in the laws and regulations, most of those firms are realizing how they need to be capitalized. The next iteration of this is making sure that their entire business has the proper oversight and control.
Craig: Oversight, oversight, oversight. They really need that, there's no getting around it and it's just getting more and more complicated.
Jeff: It is. And as firms begin to outsource investment advice and activities and all that, it just adds to the complexity of that.
Craig: Is there any limit with your system? Is there any limits on number of accounts? Would a bank with 35,000 accounts and a bank with 100,000 accounts both be able to use your solution?
Jeff: Yeah, there's no limitation. We have horizontal scale scalability so we have a distributed system, because those rules that we run every day to check everything do take time. So for our customers where there's 100,000 accounts, that takes more time than our customers that have 10,000 accounts. But we have the ability to scale that horizontally and be able to address the volume of accounts, and basically throw more hardware at our rules engine and our algorithm that basically goes through and creates all of those alerts. So we haven't found the limitation yet and we don't really expect.
Jeff: And to be honest, with the hardware technology and database technology today that's in play, we don't see an issue. Our compliance tables pale in comparison to our historical performance and market value tables; there's a lot less data in those tables, so we've stressed our tables and pieces of our applications to much greater boundaries than the compliance part of this project.
Craig: Good to know. Jeff, I really appreciate your time. This has been super informative and very helpful. Thanks for sharing all this great information with my audience.
Jeff: Craig, thank you for having me, we appreciate it. And again, if you have any other questions don't hesitate to ask. And anybody on the podcast can reach out to me at firstname.lastname@example.org.
Craig: Awesome. Have a good one, Jeff.
Craig: Hey everyone, it's Craig again. Just a few quick items before we go. If you liked this episode, please give it a five-star review on iTunes, I would very much appreciate it. And remember to check out the show notes for links to everything we talked about on this episode. For more information on wealth management technology, you can read my Wealth Management Today blog at wmtoday.com. Thanks for tuning in, and I'm looking forward to talking to you all again next week!