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Tom Richmond Of Apricity Compliance: Due Diligence Remotely

March 30, 2020

by Tom Richmond

As COVID-19 works its way around the globe and the UK has entered close to a total lockdown, financial services firms need to consider how they can continue to service their clients in a compliant and safe way.

Many financial services firms have enacted their business continuity plans (BCP). Consider your BCP: are you now able to continue business as usual, or have you found that in a real-life scenario, your BCP was ineffective?

Even if your BCP has been effective, your customers do not have BCPs of their own and some are now likely to be worried about their money, amongst many other things. So how can you help?

Keeping In Touch With Clients

The most important thing to consider is how we keep our business going whilst retaining our service standards. With government guidelines changing daily, it has been hard for many to stay up to date with whether they can go to the shops, let alone what their finances are doing.

Concerns we have heard from advisers recently include how you can complete due diligence on a customer if they are remote. There are options for this, such as the use of third-party verification systems (i.e. Smart Search, World-Check) which allow the customer to upload a copy of their identity documents to you and then you're able to verify them via a webcam call.

Other ways you can make it easier for customers to engage with you include offering them the facility to electronically sign documents online. This not only reduces the pressure on the postal service, but it also reduces the risk of inadvertent exposure through the use of physical mail.

This time has already led many of us to start looking at ways to continue working, looking after the children and how to still meet/talk to clients. There is lots of software out there which can help you remain in contact/see your customers and your colleagues - Skype, Zoom, Microsoft Teams to list just a few. For some customers and advisers, conducting meetings via the internet will be a foreign idea, but technology is something we'll all need to take advantage of.

READ: How To Use Voyant & Web Conferencing To Keep Connected With Your Clients

Capacity for Loss

As part of your advice process, you may assess many of your customers' capacity for loss. If you've already illustrated this, then for many of your customers the falls and (small) rises in the markets over recent weeks are nothing to worry about. However, no one likes to see their investment portfolio shrink.

You may want to re-run a loss capacity simulation for your clients and factor in their new portfolios/transfer values and how these lower values impact on their overall advice and investment choices.

Vulnerable Customers

Many vulnerable customers, such as those who have a pre-existing medical condition or who are older, will be feeling especially uneasy at present. As such, it is key that financial services firms identify the customers who fall under these categories and that you keep their circumstances in mind during any conversations you have with them.

You may want to contact your vulnerable clients and have a conversation with them, offering reassurance where necessary.

In A Nutshell, What You Can Do Now:

  1. Consider your firms BCP – has it worked as expected? Are there areas which could be improved?
  2. If you are still struggling to provide a continuous service to your clients, have a look at technology and software that can help you communicate and share documentation.
  3. Identify your vulnerable customers. Are you able to offer them any additional support at this trying time?
  4. Review your capacity for loss models to ensure that it is highlighting to customers the potential impact of market upheaval in global events such as this pandemic.
  5. Most importantly, stay safe.
Courtesy of Tom Richmond

Tom joined Apricity after spending nearly 10 years in a variety of compliance roles, including Financial Crime (anti money laundering, counter terrorist financing and bribery and corruption). He has experience in complaint remediation at the Financial Ombudsmen Service.

Tom holds advanced certificates in Anti Money Laundering and in Managing Sanctions Risk and a certificate in securities and investments.

The views expressed in this article are that of this author and do not necessarily reflect the views and opinions of Voyant.