So, after all the expectation, it’s happened.  With its Revised Policy Statement (10/17), the Financial Services Authority (FSA) has removed the initial exemption for mobile calls and texts.  As of 14 November 2011, therefore, financial service businesses must record all relevant electronic communications involving the giving of advice or taking of orders, to meet their regulatory obligations – including mobiles.

Yet now that the technical hurdles have been overcome, many would argue that this is no more than the formalising of what should already be regarded as good governance or best practice.  

For example, it will bring a number of benefits to financial services organisations, such as improved dispute resolution. This becomes important in the area of wealth management and private banking where relationship managers frequently have ‘relevant conversations’ (relating to the giving of advice or taking of orders) on mobile devices. 

Until now these calls have not been recorded, unlike those on fixed-line phones.  As a result, when a mistake is made, such as misinterpreting a customer’s order, the bank cannot adequately defend any claim.  This means that they must bear the sometimes substantial cost of any error or misinterpretation.  Not only does recording protect the business, equally importantly it improves customer service.

Unplanned business disruptions caused by unforeseen circumstances such as extreme weather conditions for example, have forced banks to reconsider how to equip their employees to work away from the office. In ensuring business continuity in extreme circumstances, this also extends to managing trading away from the trading floor, something which has been vigorously resisted in the past.

To be wholly effective, a mobile recording solution must address a number of key issues.  Bearing in mind the sensitivity of the financial data typically involved, from a security stand point the data must always stay in the bank’s environment and not that of the carrier.  The system must automatically record every single interaction and not rely on the agent or trader to activate the recording process. Ideally it should be a global solution, which takes account of the high level of roaming by users and that meets local regulatory compliance rules at all times.

So how to guarantee this?  The most effective way is to adopt true in-line recording, by ensuring that the recording platform is in the middle of the two parties on the call. In short, no recording, no call.  Further, a best practice solution will integrate within the bank’s existing fixed line recording platform so that all mobile and fixed line calls are recorded, stored, and retrieved in exactly the same way, whatever communications channel is used.

In summary, in light of the new regulatory demand and the other benefits which mobile recording undoubtedly brings both internally and in terms of customer service, there is no more room for doubt: the time to act is now.