Transcript Document
Compliance Training Beyond the Basics Pam Ziermann, CSCP Senior Vice President Compliance Dougherty Financial Group LLC Michele Lipschultz, MBA Manager, GCO/Enterprise L&D Thrivent Financial Michelle Canela, MSL, CSCP Sr. Compliance Manager INTECH Investment Management LLC AGENDA • Training Relevance and Alignment • Internal vs. Vendor Creation • Training Fun and Effective – Game Share – Gamification • Develop a Plan and Library • Other Topics Ideas – Training Approaches Training Relevance & Alignment • Integration with the Business – Opportunities to Partner-WIFY – Look, Read, Try & You Shall Find – E.g., New sales tools/processes-help train with compliance considerations/ perspectives? – Strategies-Align/support with training (Fin/Fraternal Integration, New Bank offering, Financial Advice center) • Firm’s mission statement or strategic goals. – Are any of the aforementioned tied to an aspect of the compliance program or culture? Integrate Regulatory Considerations Business • Review Annual Strategies & Goals-where does compliance fit, support, align? • Leverage partnership on Training Requirements-Business Training, Compliance Perspective • Be the regulatory liaison • Train Management • Use Newsletters Bake It In...New/Existing Agent/Employee Training • Set the tone - Interview & New Employee Training – Leverage agent resources/tools – How to-Effective, Engaging, Relevant Training • • Maintain a Pulse with Agent Leadership FUN with Training (Monopoly, Jeopardy, Amazing Race, movies, Springsteen) – Creativity and Innovation Worth Gold – Use gimmicks (walls, flags) • • Using 3rd parties Share the WHY… with the WIFY Training Relevance & Alignment • Risk Based Approach – Training for Risk Mitigation – Leverage Assessments– Complaint Patterns/Trends – Regulator Exam Priority Letter/Annual Focus – Target Training -Most critical risks via ACM, FE, Sup Element, Code • Risk and Role Based Approach – Increasing Relevance = One Size Fits All – Field vs. Corp – Broker Dealer RRs vs. Investment Advisor RRs • Your firm’s risk assessment – Have you adequately informed employees of the procedures/controls for your firm’s top risks? • Recent or recurring incidents or trade errors. – Have any new procedures arising from the event(s) been properly communicated to all affected employees? Tips & Tricks Share/Teach-back Your IdeasEffective & Relevant Training Internal vs. Vendor Creation Vendors Pros • Save Time • Ability to track • Diversify your training portfolio • Leverage a skill set that may be absent in your firm Cons • Canned training • Weak Instructional Design • Cost • Relevance: Firm Policy different from training • Requires too much customization Vendor Tool Box • • • • • Vetting- Key Questions Is It Check the Box? Instructionally Sound? Customizable w/low cost? Frequency of Content turnover and Course reviews? • Other Considerations in Diligence Training Fun and Effective Gerontologist video The Bully-Id Theft/AML Effective Game Ideas • Compliance Feud • Who Wants to be A Millionaire? the CCO? • Race Track Theme-Day in the Life of a RR • Monopoly • Sports Theme Make it a Competition Gamification Play and evaluate a variety of games Familiarize yourself with the game elements and how to use them Think about the learning objective and then the game Test your game Interactive Training Activity Create-Interactive Training Program Develop a Plan and Library • Use your compliance testing calendar as a guide. – Once you have a list of training topics you want to cover, compare it to your testing calendar. Are there training sessions related to testing topics? – Combine the testing and training calendars (if not too complex). – Arrange training around your firm’s cycles; i.e., are certain times of the month/quarter/year that are better than others. Develop a Plan and Library Save your training! • The training created this year is the starting point for the next session. • Modify your materials every time it is used to keep it fresh and interesting. – – – – Incorporate feedback received Update stale media elements Change things up, keep repetition to a minimum Revisit topics not covered for some time Develop a Plan and Library Save your training! • FINRA Continuing Education Assessment – New Products – New Branches – New Rules – Complaints HANDOUT PROVIDED Sample Training Library Training Approaches & Training Metric How-To’s Training Approaches • • • • HANDOUT Team Agreement PROVIDED Group/Interactive Sessions Quizzes Videos – Commercial, Customized, or links. • Computer-based, multimedia • Just in Time Training • Follow-ups to keep it fresh Training Metrics-How To How Do You Measure? How Do You Quantify the Impact? Objectives • Know Your Training Objective(s) • Kirkpatrick Four Levels - handout • Utilize course tests and evaluations – Knowledge Transfer • Behavior, Attitude and Skill Set How Training Impacts Business Documentation and MLC Awareness • 3,399 Completions • 34% Increase in Knowledge 2012 Blotter Training • 3 Courses – Average of 450 completions each • Average of 33% Increase in Knowledge Investment Advisor – PTA Reporting • 372 New accounts disclosed after June 2013 training KYC and New FINRA Rules • 3,113 Completions • 37% Increase in Knowledge Fraternity Benefit Society (FBS) How Training Impacts Business FBS 201 – Membership FBS 202 – Purpose Driven Definitions 75.3% FBS 203 – Operating Under the Lodge System 72.8% 80.0% 80.0% 70.0% 70.0% 100.0% 60.0% 80.0% 60.0% 42.4% 50.0% 50.0% 35.6% 40.0% 40.0% 60.0% 30.0% 30.0% 40.0% 20.0% 20.0% 10.0% 10.0% Post Test 87.8% 100.0% 80.0% 67.3% 0.0% Pre-Test FBS 204 – Lutheranism, Our Common Bond Post Test Pre-Test FBS 205 - Fed Tax Exemption 100.0% 81.9% 80.0% 100.0% 53.9% 40.0% 40.0% 40.0% 20.0% 20.0% 20.0% 80.6% 60.0% 0.0% Post Test 92.7% 80.0% 60.0% Pre-Test Post Test FBS 206 - Metrics and Our Mission 60.0% 0.0% 67.3% 20.0% How Training Impacts Business 0.0% 0.0% Pre-Test 90.2% 0.0% Pre-Test Post Test Pre-Test Post Test Compliance Training Beyond the Basics Questions? Appendix Interactive Training Activity – Activity/Interaction Handout Questions • What format would you use to train? • Can you come up with activities for the training participants? • What inexpensive props can you use? • What is the objective of the training? – – – • – – Dictate the type(s) of activities, interactions, practical application Groups/teams, post testing, see it, try it, do it Length of Content– • Consider appropriate level of creativity, fun, and gamification Geographic location(s) considerations Venue Selection-Online, Live, webinar – • – – • • • Chunk it, use articles/emails as reinforcement Best approach(es) based on the above: – Games, practical application via group case studies, scenarios, role plays, peer to peer teaching, videos, testing vs. training, collaboration with other applicable training • To ask relevant questions; to tap the knowledge and experience in the training Small Group Discussions Q&A Sessions – • Relevant to firm, e.g., If It Bleeds It Leads Dictate the type(s) of activities, interactions, Use Polling for Peer to Peer teaching – • • Competitive activity to reach a goal, conquer an obstacle, overcome a challenge, etc. Stimulates critical thinking, encourages memorization Role Plays Case Studies/Scenarios Stories/Storytelling – – Who is the Audience? – • Build Awareness-New Information Change a behavior or skill set Teach/enhance a skill set Tools/Resources: • Games Effective for updating skills vs. teaching new skills Question Cards – During the lecture, ask participants to write questions on the subject matter. Collect them and conduct a quiz/review session. Training Approaches - Handout Team Agreement Example We agree to: • Uphold the values of the mission statement. • “When in doubt, ask Compliance.” Training Approaches - Handout Group/Interactive Sessions • Small team interaction and learning • Practical application of the subject • Peer reinforcement Training Approaches - Handout Quizzes • Individual Tests • Group Tests – Collegial, foster interaction • Tests how effective the instruction has been. – Areas of missed communications surface • Can testing replace training? Training Approaches - Handout Videos – Commercial, Customized, or links. • Produce a training video covering actual compliance problems your firm has experienced and what it learned from those experiences. • Use as an adjunct for live training Training Approaches - Handout Computer-based, multimedia • Bad live training is as bad as bad computer training. Advantages Provable Disadvantages Less opportunity for questions Consistent messaging to audience No personal interaction Reaches everyone Inability to have live instructor to detect problems Training Approaches - Handout Just in Time • Arranging training to be provided at the point an employee needs it. – An e-mail reminder to client-facing staff regarding gift and entertainment limitations and compliance preclearance requirements before various sport season openers or before winter holidays. – Review personal trading rules with a new employee as part of the onboarding/orientation process. Training Approaches - Handout Follow-ups to keep it fresh. • Require managers/supervisors to report back with in a stated time on steps they have taken to assure their subordinates’ understanding of and compliance with what was covered in the training. • When appropriate, follow up with a “favor” if your budget allows: – Rulers with “Compliance Rules” on it. – Monitor labels with safe communication tips. – Fun size bars with “Being compliant is SWEET!” Training Library - Handout • Required training topics and other • topic ideas • • Advertising/Marketing • • Alternative Mutual Funds • • Anti-Money Laundering • • Business Recovery • • Communications with the Public • Complex Products (non-traded • REITS, mortgage backed securities, • high-yield/hard to find securities, • annuities) • • Concentration • • Conflicts of Interest (how to identify, manage and approach) • • Corporate Finance (fairness opinions, • private offerings, resale of • unregistered restricted securities) • Custody • Customer Accounts, Trade & Settlement Practices • Documentation (failure to adequately explain risk vs. return, liquidity and • leverage of) • • Due Diligence ERISA • Errors • Ethics • Expert Networks • Fees (Performance) Insider Trading (use and handling of • non-public information) • IT/Cyber Security • Managed Accounts/Fee based • Margin • Market Manipulation Markets, Exchanges & SRO’s (FINRA • oversight, Dodd-Frank, risk exams) • Money Market Funds • Municipal Advisors • Municipal Securities (new & • secondary offerings, continuing • disclosure, sales highlights/private • placements, bond offering letters, Supervisory requirements, 529 • securities and SMMP’s) New Emerging Issues (core risks) Options (disclosure document, EOW/FLEX) Outside Business Activities Personal Trading Privacy Product Knowledge and Related Supervisory Considerations Referrals Research Reports and Disclosure Retirement Rollovers/IRA’s Sales Practice, Handling of Accounts & Supervision Senior Investors Social Media (policy/trends, blogs) Soft Dollars Suitability Telemarketing Trading Practice and Abuse of TRACE (dissemination) U-4/U-5 (what is considered disclosure?) Valuation/Pricing Gamification - Handout • Conflict: – To peak interest, use some sort of conflict – Conflict has many forms • • It always represents a challenge for the learner to overcome Challenges=could be physical obstacles, combat with another player, or a puzzle Gamification - Handout • Collaboration and/or Competition: – With learning games, cooperation is often a better element to use than competition alone – Direct competition with other players can demotivate learners or set up a negative dynamic – In contrast, cooperation between players to overcome a game challenge can often motivate players and foster teamwork. – Cooperation gets people working together; competition pits people against one another. • Only one person or team wins—while everyone else loses. The players’ focus is very different depending on which element you employ or how you combine the two elements together. Competition can be appropriate, but you need to consider the outcomes it can produce. Gamification - Handout Strategy and Chance: • Strategy puts CONTROL into the learners’ realm in the form of decisions that affect gameplay or their odds of achieving the goal. • Games based heavily on CHANCE can put a learner in a highly reactive mode, one where they have little control over the outcome. Gamification - Handout • Incorporate entertaining elements to keep your audience engaged. – Related video clips • Search relevant terms like “compliance training” on YouTube and you get results like B. Braun USA’s “Corporate Compliance and Singing Prisoners,” a comical take on repercussions for excessive entertainment, or “Compliance Babies,” where twins babble is translated to explain the need for compliance to your CEO. Gamification - Handout • Current media elements; e.g., when presenting on the topic of black swan events, include an image from the “Black Swan” movie. • When appropriate, follow up with a “favor” if your budget allows: – Rulers with “Compliance Rules” on it. – Monitor labels with safe communication tips. Evaluation - Handout