"Missed by that much" Maxwell Smart (Don Adams)
All phone calls need recording, meetings annotated, emails captured and stored, and chat scrutinised. The risk is that all this data will remain unstructured - and therefore unusable.
Are you thinking what I'm thinking?
The MiFiD II directive is clear that all communications relevant to a transaction must be captured and stored for up to seven years in case of investigation. And while everyone is busy worrying about simply capturing the data, the importance of structuring these communications records is often overlooked.
- Metadata - a set of data that describes and gives information about other data.
- Good strategy – making the most of the data available by turning it into metadata.
- Bad strategy – having lots of data in warehouse without making the best use of it.
To paraphrase the directive, communications relevant to transactions need to be captured and stored. For voice this requires either call recording or annotation. Chat and email provide records of their own, assuming they cannot be deleted.
Providing all this information is collected and stored, then the regulatory hurdle is likely to be achieved. In the case of further regulatory scrutiny – for example, transaction reconstruction - whilst it will be difficult, it is not impossible.
In the case of trader surveillance, transaction triage can be arranged by sifting through hours, weeks or months of data – which may take hours weeks or months.
But collect all of it – and you’re covered…
By linking the communications data to transactions, the unstructured becomes structured. In other words, it becomes transaction metadata...
...putting an end to the KAOS.
Because of the way systems and regulations have evolved, linking communications data to transaction data is challenging, even to the most tech savvy organisations. Several existing technologies can handle linking to various levels of proficiency, and some new technologies such as artificial intelligence are also emerging that may assist.
Linking needs to happen in real time, initiated by the people creating the communications records and needs to create a data structure that can be accessed for use later on.
As mentioned above, communications data that becomes transaction metadata can be used to assist in regulatory transaction reconstruction and trader surveillance transaction triage. Aside from increased efficiencies of data retrieval, having a complete set of transaction related communications records, may provide better context around what actually happened during the pricing and execution of the transaction.
It is not a massive leap to suggest that there are other uses for transaction structured metadata. Most people I speak with in the financial services industry acknowledge that they could do more with all the data if it were structured somehow.
At the very least, business intelligence and analytics can be run across the data to create ‘actionable intelligence’ about customers, work processes or team performance. Perhaps philosophically, some reluctance to embrace this extra transparency may exist - but without doubt, better data analytics will lead to better outcomes in the longer term.
Market conduct regulations and compliance necessitate a mountain of data be collected and stored.
Real-time structuring will capture the latent benefits of all this data; both with regards to the intended purpose, as well as productivity improvements and increased customer service.
It's time to get smart...
The Revista CCM is the only platform that links communication metadata to enquiries and transactions, and enables this to happen in real time at any stage in the transaction lifecycle.