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Lights, Camera, Compliance?

Love it or hate it video calling is slowly encroaching into our daily lives. With Lloyds announcing last month that it was offering a video service to mortgage customers and other banks quick to claim they are following suit, it’s quite feasible that in a couple of years we’ll all have to be looking our best, even when working from home.

The challenge for financial organizations will come when the regulators start requiring the video element of that call be recorded. The sheer size of video data files is enough to put a significant dent in the budget, and that’s before you’ve considered the bandwidth required to store them off site.

But this doesn’t take into consideration the different types of devices people can use to make a video call or the multitude of communications tools and apps available today that facilitate it.

Then there is the need to demonstrate what documents were exchanged during a call, potentially via another channel such as email.

Each of these points adds another level of complexity in supervising, archiving, and retrieving. Even if you are not planning on recording the video element straight away, determining the approved channels now will save on wasted resources in reactive measures further down the line.

Like everything in compliance, proper record keeping is critical to maintaining communications compliance, avoiding fines, and sanctions. As a general rule of thumb most regulators will tell you that if a medium becomes a method of communication an organisation relies on, then it needs to be recorded. On this basis it’s highly probably that an audio recording would cover most scenarios where video is being used at the moment.

While there is a possibility that some unscrupulous person might hold up a sign that tells the viewer to do something illegal or unwise, the chances are slim. There are far easier ways if someone is determined to cheat the system. An audio recording would at least demonstrate that the firm was attempting to fulfil its compliance obligations and provide a fallback position in the case of litigation.

Video recording might not required now, but at some point in the future it’s likely to be added as more firms use it. If you’re revaluating your current compliance stance in relation to communications tools in preparation for MiFID II, then it makes sense to start considering what mediums are likely to have an impact in the near future, and how you can future-proof your plans to easily meet them.

 

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Financial Services Regulation

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