Compliance Review
Compliance Review Overview
Compliance is when internal programs and policy decisions are made by a company in order to meet the standards set by government laws and regulations, such as the Mutual Fund Dealers Association (MFDA), Securities and Exchange Commission (SEC), Investment Industry Regulatory Organization of Canada (IIROC), etc.
Compliance Event
A compliance event is an action or activity that needs to be reviewed from a compliance perspective. R•Broker creates the following Compliance Events:
• Trade Event
• Account Event
• KYC Event
Compliance Role Relationship
A term used to describe the connection between advisors and the compliance reviewers, or two reviewers with different compliance roles, responsible for reviewing KYC events, account events and trade events.
Examples: Corporate Tier 2 to Corporate Tier 1, or Corporate Tier 2 to Advisor.
Compliance Review Date
The date that is attached to a compliance event, usually equal to the system date on which the compliance event was created.
For example, the new account open date for an account event, the last changed date for a KYC event and the trade date for a trade event.
This term is synonymous with the term—event date.
Compliance Role
A grouping of operators that have specific compliance review tasks associated with them.
Compliance roles defined within R•Broker are:
Distribution Tier 1 (D1)—Usually a branch manager. Distribution Tier 1 reviewers must approve all outstanding compliance events that are assigned to them. Also known as the Designated Reviewer (DR).
Distribution Tier 2 (D2)—A head office compliance analyst who is responsible for Tier 2 reviews and monitoring D1 activity.
Corporate Tier 1 (C1)—A head office compliance role that is responsible for monitoring activity for anti-money laundering (AML) and anti-terrorism.
Corporate Tier 2 (C2)—A Head Office compliance role that is a 2nd level of C1, specifically responsible for monitoring AML and anti-terrorism for unusual clients.
Advisor—The individual responsible for advising the client. In terms of compliance events, this role is responsible for responding to messages (questions, clarifications, etc.) from the other compliance roles, specifically D1, C1 and C2.
Designated Reviewer
Licensed individual that performs Distributor Tier 1 review of trades and other account set up activity. Also referred to as a branch manager or Tier 1 Supervisor.
Dashboard Screens
Dashboard screens are available for each compliance role. Dashboards display the totals (counts) for the different types of compliance events that require approval or follow-up. The dashboard totals are determined through queries to the compliance data store, which will present the event counts to the reviewer. The display is always defaulted to the reviewer/operator logged on to RDUI.
Note:
If no compliance events match the queries based on the compliance data store to be displayed on the dashboard, a “Blank” field will be displayed.
The dashboard screens can be accessed based on the assigned compliance roles for the operator/advisor. If an operator has more than one compliance role assigned, by belonging to access groups with different compliance roles, then the operator will be able to access each dashboard based on the different compliance roles assigned. The dashboard will not be a consolidated view of all the applicable compliance roles for the operator. If the operator only has access to a single dashboard, it will display automatically. Otherwise, a dashboard can be selected from the drop-down list.
For the Distribution Tier 1 dashboard screen, the logged on D1 reviewer will only be able to access the compliance events based on the compliance relationship stored on the compliance event. Before displaying any events on the D1 dashboard, the system will first retrieve the Designated Reviewer and Advisor information to determine on which events are to be displayed on the D1 reviewer's dashboard.
Designated reviewer for trade events will be presented to the designated reviewer for the advisor associated with the trade, which may be different than the advisor of the account. For instance, if an advisor has placed a trade order for an account where the account has a different servicing advisor on file, then the designated reviewer for the advisor who placed the trade will have access to this trade event instead of the designated reviewer for the servicing advisor for the account.
The Alternate Reviewer function will be available on the D1 dashboard to allow the D1 reviewer to access another D1 reviewer's dashboard within the same workgroup. Once the D1 reviewer has selected another D1 reviewer's Dashboard, the alternate reviewer is able to review and approve the compliance events displayed on that dashboard. The alternate reviewer will have the same access to the Dashboard and related screens (such as KYC, Trade or Account Review Summary Screens) unless the reviewer returns to the main Dashboard screen and changes/refreshes back to the reviewer's view.
For D2, C1 and C2 reviewers, the dashboard will display the compliance events based on the operator's compliance role as well as the operator's existing workgroup security.
Different than the D1 dashboard, other compliance component's dashboards (D2, C1 and C2) do not check the designated reviewer information stored for the event to determine whether an event appears on the dashboard. The events displayed on these dashboards are based on the respective status of the compliance event (i.e. events with a D2 status other than blank are displayed on the D2 dashboard and the reviewer's workgroup security). The reviewers for D2, C1 or C2 compliance component will be able to use the advanced search function on the dashboard screen to further filter the events to display on the summary screens.
The dashboard for each compliance role has the review section separated by compliance event type (row) and compliance event status (column). The data within the dashboard table displays the selected events by Counts only that can be selected to launch the filtered compliance review summary screens for details.