Potholes & Procedures

Ah, Spring! The buds are showing on the trees and sunshine is breaking through the clouds. Here in New England, it’s the time of crocuses coming up through the soil, robins singing in the trees—and potholes forming on our streets and highways. They start out small and get progressively worse as we move into the next season, Road Construction and Detours.

Over the past few weeks, our IMP contributors have blogged about OMS compliance rules and how to spot and avoid potential errors—i.e. the proverbial potholes that can leave you and your team feeling beat up and broken down when you hit one.

Equally treacherous are the requirements in the IMAs or fund documents that cannot be automated with OMS rules and are instead tracked by manual “reminder” type rules or memorialized in procedures documents.   Like OMS rules, these manual requirements were likely captured during the initial analysis of the documentation but have not been revisited in a while.

It may be that the procedures are well known and even partially automated. For example, a report may be automated to run monthly, but delivery to the client relies on someone’s Outlook reminder or memory. During the normal course of business, those requirements are routinely handled and weaknesses in the process are not evident. Add in market volatility, staff shortages and turnover and those weaknesses are like those potholes after a rainstorm, hidden from view until someone hits one.

Instead of hoping to avoid those potholes, here are a few tips for filling them in:

1. Shared Calendar: Reminders that are set in individual calendars can easily be missed during periods of absences and turnover. Create a shared calendar for the team with deadlines and reminders.
2. In-context Procedures: Procedures should be captured in workflows.* Create workflows that articulate the steps a team member should follow to complete an important task, and ensure that those steps create an audit trail.
3. Establish Alerts: If a workflow is not completed or updated, establish an alerting mechanism to let the rest of the team know that a critical step may have been missed.
4. Post-vacation/outage review: When a team member returns from a vacation or an absence, the first order of business should be to review the workflows that were handled while he/she was out. That will ensure the returning party is up to speed and ensure that those items are checked.

*Workflows can be created a number of different tools (e.g. Sharepoint) to help facilitate proper execution and auditing. IMP's CLEAR Compliance™ platform has a workflow engine designed for compliance professionals where workflows can be linked to requirements and fully automated. Visit us at  https://www.impconsults.com/clear-compliance-solutions.