Broker Dealers and Broken Controls

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Managing a financial advisory or brokerage firm is no small task; from finding clients, to advising the ones you already have, and everything in-between, compliance and governance can be a necessary burden.  While going through the vast regulations that shape the industry, the specific tasks of testing, preserving and repeating, are often asked.  Most firms utilize Excel, Word documents, and PDFs to build out their internal policies and controls in response to these regulations.  Almost all of these controls have a quarterly, bi-annual, or annual requirement to report activities, statements, or other documents to a host of stakeholders.  While utilizing an established Excel or SharePoint solution may seem like a “good enough” practice, the risk of missing one of these control events can be detrimental to your firm.

With a strong policy management software your firm can update processes to help save time, money, and reduce overall risk.  Strunk’s Controls Manager solution is one of the most intuitive products on the market, unwinding the complexity of your policy and compliance book, so you can automate your policy controls process and operation.  Through the use of a strong organizational system to address your regulatory obligation, your firm will have a more logical and considered approach to compliance, such as a Controls Calendar, enabling your company to effortlessly respond to your requirements.

While a patchwork of common Office tools seems like the easy and cheap solution, the downside risk far outweighs the upside risk.  Strunk can help you manage these risks, and put your firm on a better strategic footing.

No better time to implement a Cloud-Based GRC Solution

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Over recent weeks, the ongoing spread of the COVID-19 coronavirus has forced companies around the country to make difficult decisions about how to protect their employees — as well as their communities as a whole.  In an effort to halt the spread of the virus, many organizations are instituting mandatory work-from-home (WFH) policies, engaging with new cloud service providers, and shifting resources toward supporting an expanding remote workforce.  The fast-moving, global reach of the coronavirus has illustrated that a forward-looking approach to risk management is more important than ever. Having a cloud-based tool that streamlines your compliance process should be in all companies’ future strategic discussions.

Strunk offers many great automated cloud-based solutions tools that streamlines compliance and risk management for our clients.  There are many benefits to these cloud-based solutions, especially in today’s environment where some many employees are working from home.  Our software is simple to implement, easy to access, very flexible and is reliable in terms of backing up data for your employees who are at different locations.  Implementing Strunk’s Risk Assessor, Policy Manager, Issue Manager and Vendor Manager software does not require extra hardware or software.  Implementing these tools can be done while business continues as usual which requires no downtime at all.  Strunk has created a new Version 2 of our Risk Assessor which is available to everyone.  Risk Assessor helps our clients complete risk assessments consistent with appropriate regulatory or standards body frameworks in days, instead of weeks.  Clients are able to upgrade for free from Version 1 to Version 2 and Strunk will help transfer results from your current Version 1 assessments.

Given the current coronavirus pandemic, the need for companies to centralize their policies and vendor management is more critical than ever.  Strunk’s Policy Manager software will organize hundreds of policy documents spread across different computer and file systems into a single editable database. With employees working remote, Policy Manager gives employee access to the companies polices for easy access and with the established review dates the system will remind employees to review the policy and make changes.  Centralizing your vendor manager process with Strunk’s Vendor Manager software will automate the process which reduces administrative burden and save time while giving employees who are working remote access to vendor due diligence, providing a practical framework for deciding which vendors to assess in depth, assessing the risks each vendor present, and the monitoring of each vendor performance.

Also, Strunk is offering additional free web training for our client’s employees.  There is no better time than now to get employees who are new or have changed job responsibilities trained on any of Strunk’s GRC software.

Strunk Policy Manager Software Now Includes GRC Policy Templates

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In 2015 Strunk launched Risk Manager which has now evolved into a full featured Governance, Risk Management, and Compliance (GRC) solution including Risk Assessor, Policy Manager, Controls Manager, Vendor Manager, Issues Manager, and Skills Manager tools.  Today, as an added service for Risk Manager clients, we are announcing the availability of standard template policies for banks, credit unions, investment advisory firms and broker-dealers.

Policy requirements evolve, and often times organizations find that their existing policy has become outdated, or they don’t have a policy at all to address a particular issue.  No one wants to write a new policy from scratch – particularly regarding a complex issue. So, starting with a vetted template and customizing it to your particular organization is a big benefit both in terms of making sure the policy is complete and saving time. There are a variety of companies that provide policy templates for a fee.  But with Strunk, they are free for Risk Manager clients.

Dan Roderick, Strunk CEO said, ‘Clients have been asking us for quite some time if we can provide them with a specific policy that they don’t currently have in their existing policy manual and each time we would track down a template example for them.  Now we have assembled a database of standard documents to respond to those requests.  In fact, if a client were to ask for an entire manual of standard policies, we can now easily provide those documents.  Policy Manager has been one of the most popular components of the Risk Manager solution – it was the first module we developed five years ago.  This should be a valuable enhancement to our GRC solution.’  The current COVID-19 crisis is one example of an event that can create a need for a new or more thorough policy.  The Pandemic Policy and Plan documents have been frequently requested during the past month.

Is your firm ready for the change in Regulation BI (Best Interest)?

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In June 2019 the United States SEC put forth changes in the way broker dealers and investment advisors deal with their customers, creating a fiduciary responsibility, and clear reporting of how your firm might be earning money from services and products provided to your clients.  These changes, while good for consumers, have created a regulatory burden on the industry to update policies and procedures, as well as formulating new ways to disclose your firm’s relationships with vendors and investment products.

The new regulation requires registered broker dealers and investment advisors to provide retail investors with easy to understand information about the confines of their relationship with your firm, ensuring potential clients can clearly see the differences between firm conflicts, fees, and other determining factors.  This has led to the creation of the CRS relationship summary form, as well as several other less formal processes all firms in the space must comply with.

While the rule changes happened in June 2019, the SEC gave the industry until June 30, 2020 to conform to the new requirements. It is generally recognized that all broker dealers and investment advisors will need to make changes to their operations, mandatory disclosures, marketing materials, and any system used for compliance.

If your firm is currently utilizing Excel, Word, and PDF documents to create your Policy Manual, it’s time to upgrade to a system that can help with the Reg BI changes and all your policy and risk management needs.  StrunkAccess provides an easy to use Policy Automation tool, allowing your firm the flexibility to find, and organize your policies in a logical way; helping to ensure compliance within your company.  Contact us today to find out more about how we can help your company achieve compliance for your regulatory needs.

Policy Management Made Easy

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Banks are required to have each and every policy approved by the board of directors on an annual basis. Many financial institutions keep their policies in Word or PDF documents on the back credenza of the officer in charge of each area of the bank. Operational and compliance policies are in the operations area of the bank; lending policies are in the chief lending officer’s file cabinet and accounting policies on the cashier’s desk.

On average, banks have between 40-60 policies that are reviewed throughout the year by the bank’s board and any changes to the policies are updated after board approval. This process can be cumbersome and hectic for most community banks. It doesn’t have to be that way!

Strunk has put together a terrific solution for managing the annual review and policy approval process. Rather than maintaining separate folders of policies, why not have them in one place with access to those who need to read, make changes, or review them periodically? That is what Strunk’s Policy Manager Program does.

Keeping a log of changes for senior management, outside auditors, or the regulators is important. Making updates or changes to policies should be easy to do. Redlined copies of the policies go to the board for approval. Your board only wants to review changes made to policies, not the entire policy. Strunk’s solution does all of this and policies are put into chapters based on each functional area of the bank. You send us your policies; we do all of the work. Access to each policy is given based on user access code. Contact us for a quick demo of the cost effective, yet comprehensive Policy Manager solution.

Strunk is pleased to announce the expansion of their offering to serve investment advisory firms and broker-dealers

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For over 40 years Strunk has been proud to work with financial institutions across the country to provide fee income strategy, risk management and compliance solutions. We are now bringing the power and reliability of our software applications to serve investment advisory firms and broker-dealers.

Any organization wants to be sure it has adequate policies and procedures in place to address the risks it faces. Strunk’s Policy Manager application is the perfect tool to help organize and manage these documents into a firm’s comprehensive compliance manual.

Due to the breadth of rulemakings and interpretations brought forth by the Securities and Exchange Commission that these organizations must adopt, internal policies and procedures are not only numerous but can be difficult to maintain. Strunk’s Policy Manager provides a structured, centralized single source of truth for this documentation.  Dan Roderick, Strunk CEO commented, “Five years ago, our very first client for Policy Manager happened to be a broker-dealer and investment advisory firm, so it only makes sense for us to place additional focus on that market”.

The solution features linkage of procedures to polices, automated change logging, as well as the ability to add multiple file attachments to each document. It is also possible to map policies to relevant risk assessment frameworks to make sure all bases are covered.

Additionally, the ability to assign ownership responsibilities at the section or individual policy level will provide granular control over read, edit and approval rights. Companies will be able to track employee acknowledgement of reading specific policies through application logs and reports. When users make changes to documents these updates will be automatically logged and logs can be filtered by particular time period or user.

PDFs can be produced from all documentation for external consumption along with redline versions of policy changes for comparison.

 

An independent certified public accountant has examined Strunk’s operations and found them to be in compliance with the AICPA’s Trust Service Principles. It was determined that Strunk meets the Security, Availability, Processing Integrity, Confidentiality, and Privacy criteria for SOC 2 established by the AICPA.