Burr & Forman

05.29.2020   |   Blog Articles, FINRA, Securities Litigation

FINRA Shares Firms’ WFH Practices

On May 28, 2020, FINRA issued its Regulatory Notice 20-16 sharing firms’ WFH practices observed to date.  They include common practices adopted across most industries, as one would expect.

During the TRANSITION TO WFH, firm practices included:

  • Increased Customer Assistance through outreach and web-based communications, to ensure customers knew how to access representatives and other resources;
  • Location Monitoring & Contact Lists to know where staff were and ensure they knew how to stay in touch;
  • Increased Support for staff, including more frequent training and communications, and increased tech support; and,
  • Heightened Focus on Confidentiality and CyberSecurity issues, including reminders, training and monitoring of heightened risks.


WFH SUPERVISION
efforts included:

  • Increased Communications;
  • More Frequent Meetings, with greater regularity;
  • Increased Supervision, through supervisory checklists, remote affirmations, and encouragement to “over-escalate” issues to supervisors and management; and,
  • Monitoring of Emerging Risks.


TRADING SUPERVISION
included additional precautions attempting to replicate virtually various “line of sight” supervisory techniques, including:

  • Pre-screens with reminders and affirmations;
  • Surveillance through lowered reporting thresholds and increased scope of trade or exception reporting; and,
  • New Monitoring Techniques, for example, always-on web-cams, frequent check-ins or roll-calls, and recording of real-time chat-rooms.

FINRA Reg. Notice 20-16 is here.

Thomas K. Potter, III (tpotter@burr.com) is a partner in the Securities Litigation Practice Group at Burr & Forman, LLP. Tom is licensed in Tennessee, Texas, and Louisiana. He has over 34 years of experience representing financial institutions in litigation, regulatory, and compliance matters. See attorney profile.

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