Time to Get Used to Hybrid Work

As we discussed mitigation strategies and best practices, the panelists noted several areas where they have prepared for the next normal, including:

Hardened governance processes. Firms have learned from prior mishaps of IT rollout of tools before they’ve been properly vetted for risk. Whether as a dedicated process, or a multiple-person committee, financial organizations should involve direct engagement and collaboration with legal, security, compliance, and privacy teams to adequately assess risk for each new tool.

Feature-level due diligence. Panelists discussed how important it is for compliance professionals and teams to understand the capabilities of new tools. This is especially critical given the lack of prescriptive regulatory guidance. Compliance should be examining how new communications tools will be used, by whom, how frequently, and what alternatives exist.

Economic models are evolving. Several comments centered on how firms can manage the cost of evaluating, licensing, and supporting new platforms. While some have considered passing some portion of the cost on to the advisor, they’ve stopped short of considering client-pull for new tools or driving advisors to sketchy alternative tools (e.g., freeware).

Monitoring for prohibited tools intensifies. Lessons from Roaring Kitty and the SEC's emphasis on outside business activities were not lost on the panel. Suggestions included the modification of lexicons to look for prohibited networks, updated written supervisory procedures, as well the use of attestations from employees as measures to stay in front of this very visible topic.

The visibility gap continues. Financial firms remain focused on the loss of visibility into the activities of hybrid workers. Panelists advocated for:

• Using gap analyses to identify areas that may be unintentionally biased toward in-person policy inspection
• Codifying policy items that are unique to remote work
• Awareness of the specific locations of remote staff, to meet branch location registration requirements in each state

Keeping up with the volume and variety of data. Financial firms are struggling to keep up with the volume and variety of communications content being generated every day. For many, adding supervisory staff is not an option, and the tuning of lexicons can get to a point of diminishing, marginal returns. The goal of becoming more efficient with technology will lead some toward artificial intelligence and machine learning solutions faster than originally planned.

Clearly, the phrase “back to normal” is as inaccurate as the notion of going “back to work.” Aside from the unknown fate of large in-person industry conferences, the virtual workplace has become the norm, at least for the foreseeable future. The advisor is the branch as the employee is the office, whether that means a physical or virtual presence or both. It’s time for firms to ensure that their compliance controls are equally effective in a future with WFH, WFA, or WFCB.