The inventive subject matter relates generally to process automation and more particularly to electronic automation of financial advisory services.
There is now widespread and almost universal use of computers, software and electronic communications and data exchange in the information services industry in general and in the financial advisory services industry by example. These tools have increased productivity by a large measure over time by simplifying and automating many tasks that were previously carried out using tedious and time consuming manual calculations or report generation. Nonetheless, there continue to be many inefficiencies in the way these tools are used day in and day out, and also in the way the tools interact with one another. Further, there have been important changes in the regulation of the financial advisory services industry. These changes have imposed more exacting regulations on the industry, and now require more vigilant compliance by financial advisors and their employers, agents or affiliations.
Systems and methods of the embodiments of the inventive subject matter provide for automation of information service work, for example the work of financial advisors and for enforcing and facilitating the adherence of such information workers to regulatory requirements.
In the following description, numerous specific details are set forth. However, it is understood that embodiments of the invention may be practiced without these specific details. In other instances, well-known circuits, structures, and techniques have not been shown in detail to avoid obscuring the understanding of this description. Note that in the description, references to “one embodiment” or “an embodiment” mean that the feature being referred to is included in at least one embodiment of the invention. Further, separate references to “one embodiment” in this description do not necessarily refer to the same embodiment; and, neither are such embodiments mutually exclusive, unless so stated and except as will be readily apparent to those of ordinary skill in the art. Thus, the present invention can include any variety of combinations and/or integrations of the embodiments described herein. Moreover, in this description, the phrase “exemplary embodiment” means that the embodiment being referred to serves as an example or illustration.
Described below are systems and methods for creating electronic workflows for use, in one example embodiment, for implementing written policies and procedures and preventing violations of the Advisor's Act as set forth in SEC Rule 206 and 204a1. According to this Act, there are requirements, for instance, for enforcing policies that enforce proper conduct in accordance with fiduciary duties. The Act requires, also, for instance, that financial service companies keep copies of policies and records and an audit trail demonstrating at least an annual review of compliance. According to one example embodiment, there is provided a process wherein existing policies and procedures are reviewed and mapped against regulatory requirements, and augmented as necessary to address compliance and audit requirements. In the process, the existing or current processes are captured and translated into workflow diagrams. The workflow is then additionally analyzed for cost, consistency and the effectiveness of the procedures. From this analysis recommendations to improve the processes are formulated.
According to one example embodiment of the inventive subject matter, there are provided systems and methods for automating and streamlining procedures based on the analysis, such that the procedures generate required audit trails which prove implementation without extra effort by employees. In addition, the workflow may integrate with current systems using flexible technologies, and provide tools that allow employees to learn and perform compliance functions in one easy process. Further, the method and system may highlight who does and does not complete responsibilities. Such reporting may be generated instantaneously. This allows a using organization to prove the implementation of its policies and procedures and build tools that enable the organization to train employees and agents in compliance procedures. While the agents are performing the procedures in a workflow, the workflow ensures that the processes meet regulations and are consistently applied. Activities are documented while they are occurring, providing instantaneous records of what was done by whom, when and where. Thus, the process and system provide for identifying any or all 10 compliance areas based on those areas. Regulatory requirements may be imposed by laws or by rules enacted in accordance with laws, or in another example embodiment may be imposed by voluntary industry standards such as generally accepted accounting principles.
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Workflow system 100 may also be connected, as indicated, to one or more external systems such as accounting systems 150, electronic trading systems 152 (for trading, for instance, debt and equity instruments), customer service systems 154, portfolio management systems 156, e-mail systems 158 and any other sources, repositories or processing destinations for data. In one embodiment, but not by way of limitation, workflow system 100 may interface with such systems using an industry standard interface such as XML/SOAP or other web services based protocols, allowing system 100 to query, write and exchange data with the external systems.
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Creation of generalized workflows (for example workflows that are generally applicable to a particular set of tasks and can be customized) may be formed from a library of workflow components 250 (which also can be stored in memory 214 or storage 216) that have been previously assembled, wherein such operations may include, for instance, tasks and subtasks used to collect data from an external system, send data to an external system, create merge documents, and escalate an issue. As such, workflow modeling system 200 may include a data structure and storage area for storing a component library of generalized or modifiable workflow data that can be used to build generalized workflows, or modify generalized workflows. Components 250 also may be made compliant with SEC regulations.
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According to one example embodiment of the inventive subject matter, the generalized modeled workflow 340 may represent an electronic workflow used by a financial advisor or his staff to:
Each generalized modeled workflow 340 is designed to assure compliance with one or more United States Securities and Exchange Commission (SEC) regulations governing the provision of services by a financial advisor or financial service company to a client of the advisor or company. Such SEC regulations are, in one example embodiment, SEC Rule 206-4-7, which sets forth ten policies that financial advisor service providers are required to implement in their organizations. Such policies include, for example, the following:
According to one example embodiment, the generalized modeled workflow 340 provides one or more configuration options that may be selected by a user such as a financial services organization to customize the workflow 340 to their particular liking or needs to create a customized, SEC compliant workflow 350. According to another example embodiment, the options presented to a user designed to be compliant with any SEC regulations applicable to the workflow in question. The options may be presented in drop down menus or in one or more other screens providing mechanisms to input configuration choices. Accordingly, a user is allowed to configure a workflow to their particular needs or liking while at the same time knowing that any such configuration will result in a customized workflow that is compliant with SEC regulations. Configurations may include such items as names, addresses, roles, audit trails options, escalation options, timing options and other options.
Accordingly, according to one example embodiment, a user or user organization may use the configuration system 300 to configure and customize one or more generalized, SEC compliant workflows for use, for example, by its financial advisors. Because the workflows 350 are known to be compliant with SEC regulations, the organization gains confidence that its financial advisors will act in accordance with SEC regulations and policies provided that they follow the customized workflows 350.
According to another example embodiment, the customized workflows 350 may also be further modified manually to achieve alternate or additional workflow, but such workflows would not necessarily be known to satisfy SEC regulations without further review and clearance by appropriate personnel.
A customized workflow 350 may be represented by configuration data stored in a customized process model data structure 360, which may be interpreted for display and manipulation on a computer monitor. Software module 320 may, in one mode of operation, compile or otherwise process the customized configuration data to generate customized workflow programming code such as BPEL code 370 that can be executed by the workflow operating system 120 to perform customized electronic workflow operations.
According to one example embodiment, a workflow may be modeled in a hierarchy of policy to procedure to rule to workflow programming code such as BPEL code, wherein a procedure is designed to implement a policy, and the procedure includes one or more rules, and the rules are used to generate workflow programming code such as BPEL code.
According to one example embodiment, a SEC compliant workflow 340 or 350 implements audit capabilities to conform to SEC audit requirements, and escalation capabilities, wherein excursions from policy compliant actions can be escalated to parties responsible for managing or auditing compliance with SEC regulations or other compliance.
According to another example embodiment, BPEL code 370 executes on the workflow system 100 and provides a workflow interface for use by a financial service advisor. System 100 may also provide an interface for an administrator permitting the setting of personnel, roles and privileges and to specify how escalation may occur such as by e-mails to certain personnel. A compliance dashboard display may be provided by the BPEL code 370 to allow personnel to monitor a workflow and make sure that the proper steps have been followed, for example, to monitor whether proper documentation has been submitted.
According to another example embodiment, a generalized workflow is assembled by first studying a process used by a financial advisor, for example, by observing the financial advisor, and then modeling the observed behavior, and finally adding compliance steps or operations that assures that the particular workflow being performed is compliant with applicable SEC regulations.
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Thus, there has been described above in one embodiment electronic workflow creation and execution systems and methods for use in the financial services industry. According to another embodiment, the creation and execution systems and methods may be used for industries or applications other than in the financial services industry. For example, the systems and methods are applicable to the legal services industry to assure compliance with laws or regulations, or to any industry that is regulated by law or rule or by voluntary compliance with an industry standard.
This application claims priority to U.S. Provisional Application No. 60/651,024, filed Feb. 8, 2005.
Number | Date | Country | |
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60651024 | Feb 2005 | US |