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.
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–
–
–
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?
–
–
–
•
–
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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
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•
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•
•
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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
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•
Relevant to firm, e.g., If It Bleeds It Leads
Dictate the type(s) of activities, interactions,
Use Polling for Peer to Peer teaching
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•
•
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
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Who is the Audience?
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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