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Selecting and Implementing Technology for
Advertising Compliance

Insurance Advertising Compliance Association Annual Conference
April 12, 2013




Mark F. Catone
Vice President, National Regulatory Services
Selecting an advertising Compliance Solution is similar to
  selecting any vendor-based solution for your company


      Requirements        Vendor Profile        Request for           Vendor             Solution
       Gathering            Creation             Proposal            Selection        Implementation




 • I will not spend much time on the overall process as the evaluation and selection
   process itself as it is fairly well established

 • My goal for today is to highlight key tips that can assist you in selecting and
   implementing a technology solution

 • The same features and criteria can be applied to be applied to an internally
   developed system, rather than an external vendor




When I mention a vendor solution, it assumes employing an externally hosted or “Software-as-a-
                    Service” platform because of the economics involved
Top features to look for in an advertising compliance technology
solution
                                                     •   Increased efficiency and reduction in time and cost to
• Conversion of manual, paper and ad-hoc
  compliance process to an electronic form
                                                        review and process materials
                                                     •   Elimination of paper, emails and review processes
                                                     •   The compliance workflow can be configured to meet the
                                                         firms needs
• Ability to scale and adapt as needed              •   Economical and straightforward to add and manage
                                                         users, volume and adapt to new needs
                                                     •   Tracking by business unit, product or office for
• Measure and improve compliance
  processes and areas of risk
                                                        submissions, reviews and changes
                                                     •   Reporting on volume, review turnaround, other metrics
                                                     •   Enforce compliance policy and metrics
                                                     •   Documents the lifecycle of each submission (who, what,
                                                         when and where)
                                                     •   Data accuracy is enhanced which reduces risk by limiting
• Significantly improves of the firms risk
  profile
                                                        human error
                                                     •   Archives and retains all copies and changes made
                                                         through to the final version and meets data storage
                                                         regulatory requirements
                                                     •   Supports regulatory examinations or internal requests
                                                     •   Data security is a top priority
• Must be secure, available and reliable            •   Needs to be available on-demand
                                                     •   Supports Disaster Recovery and BCP
                                                     •   Modest timeline until the firm sees a return on
• Can be economically implemented and
  managed
                                                        investment (ROI)
                                                     •   Total Cost of Ownership (TCO)



        For the rest of the presentation, we will look at key aspects of these 6 areas
Converting to an electronic process connects
    stakeholders though workflow, forms and attachments
• Electronically file
  materials to external
  regulators who have
  an electronic system-
  to-system gateway
                                                                       • Track state filing status
                                                                         and include filed
                                                                         documents and other
                                                                         meta data




                • Connect the key stakeholder departments and users
                  electronically allowing submission and review of materials by the
                  appropriate parties at the appropriate time
Top features to look for in an advertising compliance technology
solution
                                                     •   Increased efficiency and reduction in time and cost to
• Conversion of manual, paper and ad-hoc
  compliance process to an electronic form
                                                        review and process materials
                                                     •   Elimination of paper, emails and review processes
                                                     •   The compliance workflow can be configured to meet the
                                                         firms needs
• Ability to scale and adapt as needed              •   Economical and straightforward to add and manage
                                                         users, volume and adapt to new needs
                                                     •   Tracking by business unit, product or office for
• Measure and improve compliance
  processes and areas of risk
                                                        submissions, reviews and changes
                                                     •   Reporting on volume, review turnaround, other metrics
                                                     •   Enforce compliance policy and metrics
                                                     •   Documents the lifecycle of each submission (who, what,
                                                         when and where)
                                                     •   Data accuracy is enhanced which reduces risk by limiting
• Significantly improves of the firms risk
  profile
                                                        human error
                                                     •   Archives and retains all copies and changes made
                                                         through to the final version and meets data storage
                                                         regulatory requirements
                                                     •   Supports regulatory examinations or internal requests
                                                     •   Data security is a top priority
• Must be secure, available and reliable            •   Needs to be available on-demand
                                                     •   Supports Disaster Recovery and BCP
                                                     •   Modest timeline until the firm sees a return on
• Can be economically implemented and
  managed
                                                        investment (ROI)
                                                     •   Total Cost of Ownership (TCO)



        For the rest of the presentation, we will look at key aspects of these 6 areas
And allows you to scale a solution for addition of users, external
integration or automated user updates
  Compliance & Supervision                                    External Integration
                                                     • Electronically file where
                                                       feasible


                                                                                     Tracking and Reporting

• Compliance can
  review, approve or
  reroute materials in
  process                                                                • Tracking shows the status of
                                                                           individual projects in process
                                                                         • Reporting shows areas of risk
                                                                           and performance
                                                                         • Export reports to Microsoft
                                                                           Office


                                                                                            User &
                                                                                            Organization
                                                                                            Updates

                             • Workflow and routing permits
                               each stakeholder to play                 • Automate user and
                               their role, electronically                 supervisory updates
                                                                        • Integration with
Legal, Marketing, Research                                                internal systems
A typical workflow for an organization should be configurable to
             the firms compliance process
Swim Lanes




             In this example, there are two roles, a submitter an approver and an electronic submission
                                      process to FINRA (shown on the bottom)
Top features to look for in an advertising compliance technology
solution
                                                     •   Increased efficiency and reduction in time and cost to
• Conversion of manual, paper and ad-hoc
  compliance process to an electronic form
                                                        review and process materials
                                                     •   Elimination of paper, emails and review processes
                                                     •   The compliance workflow can be configured to meet the
                                                         firms needs
• Ability to scale and adapt as needed              •   Economical and straightforward to add and manage
                                                         users, volume and adapt to new needs
                                                     •   Tracking by business unit, product or office for
• Measure and improve compliance
  processes and areas of risk
                                                        submissions, reviews and changes
                                                     •   Reporting on volume, review turnaround, other metrics
                                                     •   Enforce compliance policy and metrics
                                                     •   Documents the lifecycle of each submission (who, what,
                                                         when and where)
                                                     •   Data accuracy is enhanced which reduces risk by limiting
• Significantly improves of the firms risk
  profile
                                                        human error
                                                     •   Archives and retains all copies and changes made
                                                         through to the final version and meets data storage
                                                         regulatory requirements
                                                     •   Supports regulatory examinations or internal requests
                                                     •   Data security is a top priority
• Must be secure, available and reliable            •   Needs to be available on-demand
                                                     •   Supports Disaster Recovery and BCP
                                                     •   Modest timeline until the firm sees a return on
• Can be economically implemented and
  managed
                                                        investment (ROI)
                                                     •   Total Cost of Ownership (TCO)



        For the rest of the presentation, we will look at key aspects of these 6 areas
Because forms are electronic, they can enforce policy,
 significantly improve data integrity and improve collaboration
                                                         Elements, Controls and Fields
                                                         • Checkbox’s, drop down lists, radio
                                                           buttons, masked fields and date
                                                           pickers reduce data errors.




 Document Annotation
 Tools
 • Reviewers can annotate
   changes
 • All changes are tracked on
   each version



All elements should be configurable, so changes can be
            quickly to adapt to new needs
Status Dashboards and reporting for monitoring and managing
the compliance process
                                                                               Elements, Controls and Fields
                                             Easy to use dashboard
                                                                              • Checkbox’s, drop down lists, radio
                                             • See the status of any review, who buttons, masked fields and date
                                               has it and other information “at-a-pickers reduce data errors.
                                               glance”
                                             • Export all status and transaction
                                               information to Microsoft Office


         Status History Report
         • Shows the entire history of the
           review process for any given
           material



                                                                            Turn-Around-Time Report
                                                                            • Helps manage review response times
                                                                              to submission requests
                                                                            • Also used to measure the
                                                                              performance of reviewers or staff
Top features to look for in an advertising compliance technology
solution
                                                     •   Increased efficiency and reduction in time and cost to
• Conversion of manual, paper and ad-hoc
  compliance process to an electronic form
                                                        review and process materials
                                                     •   Elimination of paper, emails and review processes
                                                     •   The compliance workflow can be configured to meet the
                                                         firms needs
• Ability to scale and adapt as needed              •   Economical and straightforward to add and manage
                                                         users, volume and adapt to new needs
                                                     •   Tracking by business unit, product or office for
• Measure and improve compliance
  processes and areas of risk
                                                        submissions, reviews and changes
                                                     •   Reporting on volume, review turnaround, other metrics
                                                     •   Enforce compliance policy and metrics
                                                     •   Documents the lifecycle of each submission (who, what,
                                                         when and where)
                                                     •   Data accuracy is enhanced which reduces risk by limiting
• Significantly improves of the firms risk
  profile
                                                        human error
                                                     •   Archives and retains all copies and changes made
                                                         through to the final version and meets data storage
                                                         regulatory requirements
                                                     •   Supports regulatory examinations or internal requests
                                                     •   Data security is a top priority
• Must be secure, available and reliable            •   Needs to be available on-demand
                                                     •   Supports Disaster Recovery and BCP
                                                     •   Modest timeline until the firm sees a return on
• Can be economically implemented and
  managed
                                                        investment (ROI)
                                                     •   Total Cost of Ownership (TCO)



        For the rest of the presentation, we will look at key aspects of these 6 areas
A compliance platform must be scaleable,
secure and reliable                                                                                         UK / EU Hosting


   Infrastructure and Security                                                                                            Firewall
                                                Secondary Data Center and DR
• Secure, SaaS Web-based
                                                USA #2
  application (Software-as-a-Service)

• SSL Encryption                                                                                         Firewall
                                           Primary Data Center
                                           USA #1
• SSAE 16 SOC 1 Type II (formerly SAS 70
  Type II)
                                                                                              Firewall

• Record retention (7 years)

• 17a-4 Books and Records Compliant           End users

                                                                                                                    Internet
• Full DR Backup

• Secure data transfer
                                           Your location #1

• Optional Single-Sign-On from
  company portal                                                                                               Firewall
                                                              Your location #2

• EU Safe Harbor certified
                                                                           Your location #N




Many factors contribute to the scalability, security and reliability of a compliance
               platform whether hosting few users or thousands
Top features to look for in an advertising compliance technology
solution
                                                     •   Increased efficiency and reduction in time and cost to
• Conversion of manual, paper and ad-hoc
  compliance process to an electronic form
                                                        review and process materials
                                                     •   Elimination of paper, emails and review processes
                                                     •   The compliance workflow can be configured to meet the
                                                         firms needs
• Ability to scale and adapt as needed              •   Economical and straightforward to add and manage
                                                         users, volume and adapt to new needs
                                                     •   Tracking by business unit, product or office for
• Measure and improve compliance
  processes and areas of risk
                                                        submissions, reviews and changes
                                                     •   Reporting on volume, review turnaround, other metrics
                                                     •   Enforce compliance policy and metrics
                                                     •   Documents the lifecycle of each submission (who, what,
                                                         when and where)
                                                     •   Data accuracy is enhanced which reduces risk by limiting
• Significantly improves of the firms risk
  profile
                                                        human error
                                                     •   Archives and retains all copies and changes made
                                                         through to the final version and meets data storage
                                                         regulatory requirements
                                                     •   Supports regulatory examinations or internal requests
                                                     •   Data security is a top priority
• Must be secure, available and reliable            •   Needs to be available on-demand
                                                     •   Supports Disaster Recovery and BCP
                                                     •   Modest timeline until the firm sees a return on
• Can be economically implemented and
  managed
                                                        investment (ROI)
                                                     •   Total Cost of Ownership (TCO)



        For the rest of the presentation, we will look at key aspects of these 6 areas
The growth of hosted solutions are due to a faster time-to-
market and lower overall costs
  Manage or build internally            License externally
                                          and configure

     Training / Roll-out
                                                                     Software-as-a-Service
                                                                         business value

     Configuration                                              •   Faster time to value
                                                                •   Lower TCO
                                                                •   Assured business value
     Implementation Design                                      •   Predictable cost

                                     Training / Roll-out     Low-user impact
                                     Configuration           Users, forms, workflow, external
     Compliance                                              system integration
     framework and                   Implementation
     workflow                        Design                  Tailored for the way you do business
     requirements
                                     Compliance
                                     framework and
                                     workflow
                                                             Goals, modules, workflow, options
                                     requirements

       Months or Years                Weeks or Months




  Because hosted solutions are share resources across many customers,
                       they are more economical
Thank You

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Selecting and Implementing Insurance Advertising Compliance Technology Solutions

  • 1. Selecting and Implementing Technology for Advertising Compliance Insurance Advertising Compliance Association Annual Conference April 12, 2013 Mark F. Catone Vice President, National Regulatory Services
  • 2. Selecting an advertising Compliance Solution is similar to selecting any vendor-based solution for your company Requirements Vendor Profile Request for Vendor Solution Gathering Creation Proposal Selection Implementation • I will not spend much time on the overall process as the evaluation and selection process itself as it is fairly well established • My goal for today is to highlight key tips that can assist you in selecting and implementing a technology solution • The same features and criteria can be applied to be applied to an internally developed system, rather than an external vendor When I mention a vendor solution, it assumes employing an externally hosted or “Software-as-a- Service” platform because of the economics involved
  • 3. Top features to look for in an advertising compliance technology solution • Increased efficiency and reduction in time and cost to • Conversion of manual, paper and ad-hoc compliance process to an electronic form  review and process materials • Elimination of paper, emails and review processes • The compliance workflow can be configured to meet the firms needs • Ability to scale and adapt as needed  • Economical and straightforward to add and manage users, volume and adapt to new needs • Tracking by business unit, product or office for • Measure and improve compliance processes and areas of risk  submissions, reviews and changes • Reporting on volume, review turnaround, other metrics • Enforce compliance policy and metrics • Documents the lifecycle of each submission (who, what, when and where) • Data accuracy is enhanced which reduces risk by limiting • Significantly improves of the firms risk profile  human error • Archives and retains all copies and changes made through to the final version and meets data storage regulatory requirements • Supports regulatory examinations or internal requests • Data security is a top priority • Must be secure, available and reliable  • Needs to be available on-demand • Supports Disaster Recovery and BCP • Modest timeline until the firm sees a return on • Can be economically implemented and managed  investment (ROI) • Total Cost of Ownership (TCO) For the rest of the presentation, we will look at key aspects of these 6 areas
  • 4. Converting to an electronic process connects stakeholders though workflow, forms and attachments • Electronically file materials to external regulators who have an electronic system- to-system gateway • Track state filing status and include filed documents and other meta data • Connect the key stakeholder departments and users electronically allowing submission and review of materials by the appropriate parties at the appropriate time
  • 5. Top features to look for in an advertising compliance technology solution • Increased efficiency and reduction in time and cost to • Conversion of manual, paper and ad-hoc compliance process to an electronic form  review and process materials • Elimination of paper, emails and review processes • The compliance workflow can be configured to meet the firms needs • Ability to scale and adapt as needed  • Economical and straightforward to add and manage users, volume and adapt to new needs • Tracking by business unit, product or office for • Measure and improve compliance processes and areas of risk  submissions, reviews and changes • Reporting on volume, review turnaround, other metrics • Enforce compliance policy and metrics • Documents the lifecycle of each submission (who, what, when and where) • Data accuracy is enhanced which reduces risk by limiting • Significantly improves of the firms risk profile  human error • Archives and retains all copies and changes made through to the final version and meets data storage regulatory requirements • Supports regulatory examinations or internal requests • Data security is a top priority • Must be secure, available and reliable  • Needs to be available on-demand • Supports Disaster Recovery and BCP • Modest timeline until the firm sees a return on • Can be economically implemented and managed  investment (ROI) • Total Cost of Ownership (TCO) For the rest of the presentation, we will look at key aspects of these 6 areas
  • 6. And allows you to scale a solution for addition of users, external integration or automated user updates Compliance & Supervision External Integration • Electronically file where feasible Tracking and Reporting • Compliance can review, approve or reroute materials in process • Tracking shows the status of individual projects in process • Reporting shows areas of risk and performance • Export reports to Microsoft Office User & Organization Updates • Workflow and routing permits each stakeholder to play • Automate user and their role, electronically supervisory updates • Integration with Legal, Marketing, Research internal systems
  • 7. A typical workflow for an organization should be configurable to the firms compliance process Swim Lanes In this example, there are two roles, a submitter an approver and an electronic submission process to FINRA (shown on the bottom)
  • 8. Top features to look for in an advertising compliance technology solution • Increased efficiency and reduction in time and cost to • Conversion of manual, paper and ad-hoc compliance process to an electronic form  review and process materials • Elimination of paper, emails and review processes • The compliance workflow can be configured to meet the firms needs • Ability to scale and adapt as needed  • Economical and straightforward to add and manage users, volume and adapt to new needs • Tracking by business unit, product or office for • Measure and improve compliance processes and areas of risk  submissions, reviews and changes • Reporting on volume, review turnaround, other metrics • Enforce compliance policy and metrics • Documents the lifecycle of each submission (who, what, when and where) • Data accuracy is enhanced which reduces risk by limiting • Significantly improves of the firms risk profile  human error • Archives and retains all copies and changes made through to the final version and meets data storage regulatory requirements • Supports regulatory examinations or internal requests • Data security is a top priority • Must be secure, available and reliable  • Needs to be available on-demand • Supports Disaster Recovery and BCP • Modest timeline until the firm sees a return on • Can be economically implemented and managed  investment (ROI) • Total Cost of Ownership (TCO) For the rest of the presentation, we will look at key aspects of these 6 areas
  • 9. Because forms are electronic, they can enforce policy, significantly improve data integrity and improve collaboration Elements, Controls and Fields • Checkbox’s, drop down lists, radio buttons, masked fields and date pickers reduce data errors. Document Annotation Tools • Reviewers can annotate changes • All changes are tracked on each version All elements should be configurable, so changes can be quickly to adapt to new needs
  • 10. Status Dashboards and reporting for monitoring and managing the compliance process Elements, Controls and Fields Easy to use dashboard • Checkbox’s, drop down lists, radio • See the status of any review, who buttons, masked fields and date has it and other information “at-a-pickers reduce data errors. glance” • Export all status and transaction information to Microsoft Office Status History Report • Shows the entire history of the review process for any given material Turn-Around-Time Report • Helps manage review response times to submission requests • Also used to measure the performance of reviewers or staff
  • 11. Top features to look for in an advertising compliance technology solution • Increased efficiency and reduction in time and cost to • Conversion of manual, paper and ad-hoc compliance process to an electronic form  review and process materials • Elimination of paper, emails and review processes • The compliance workflow can be configured to meet the firms needs • Ability to scale and adapt as needed  • Economical and straightforward to add and manage users, volume and adapt to new needs • Tracking by business unit, product or office for • Measure and improve compliance processes and areas of risk  submissions, reviews and changes • Reporting on volume, review turnaround, other metrics • Enforce compliance policy and metrics • Documents the lifecycle of each submission (who, what, when and where) • Data accuracy is enhanced which reduces risk by limiting • Significantly improves of the firms risk profile  human error • Archives and retains all copies and changes made through to the final version and meets data storage regulatory requirements • Supports regulatory examinations or internal requests • Data security is a top priority • Must be secure, available and reliable  • Needs to be available on-demand • Supports Disaster Recovery and BCP • Modest timeline until the firm sees a return on • Can be economically implemented and managed  investment (ROI) • Total Cost of Ownership (TCO) For the rest of the presentation, we will look at key aspects of these 6 areas
  • 12. A compliance platform must be scaleable, secure and reliable UK / EU Hosting Infrastructure and Security Firewall Secondary Data Center and DR • Secure, SaaS Web-based USA #2 application (Software-as-a-Service) • SSL Encryption Firewall Primary Data Center USA #1 • SSAE 16 SOC 1 Type II (formerly SAS 70 Type II) Firewall • Record retention (7 years) • 17a-4 Books and Records Compliant End users Internet • Full DR Backup • Secure data transfer Your location #1 • Optional Single-Sign-On from company portal Firewall Your location #2 • EU Safe Harbor certified Your location #N Many factors contribute to the scalability, security and reliability of a compliance platform whether hosting few users or thousands
  • 13. Top features to look for in an advertising compliance technology solution • Increased efficiency and reduction in time and cost to • Conversion of manual, paper and ad-hoc compliance process to an electronic form  review and process materials • Elimination of paper, emails and review processes • The compliance workflow can be configured to meet the firms needs • Ability to scale and adapt as needed  • Economical and straightforward to add and manage users, volume and adapt to new needs • Tracking by business unit, product or office for • Measure and improve compliance processes and areas of risk  submissions, reviews and changes • Reporting on volume, review turnaround, other metrics • Enforce compliance policy and metrics • Documents the lifecycle of each submission (who, what, when and where) • Data accuracy is enhanced which reduces risk by limiting • Significantly improves of the firms risk profile  human error • Archives and retains all copies and changes made through to the final version and meets data storage regulatory requirements • Supports regulatory examinations or internal requests • Data security is a top priority • Must be secure, available and reliable  • Needs to be available on-demand • Supports Disaster Recovery and BCP • Modest timeline until the firm sees a return on • Can be economically implemented and managed  investment (ROI) • Total Cost of Ownership (TCO) For the rest of the presentation, we will look at key aspects of these 6 areas
  • 14. The growth of hosted solutions are due to a faster time-to- market and lower overall costs Manage or build internally License externally and configure Training / Roll-out Software-as-a-Service business value Configuration • Faster time to value • Lower TCO • Assured business value Implementation Design • Predictable cost Training / Roll-out Low-user impact Configuration Users, forms, workflow, external Compliance system integration framework and Implementation workflow Design Tailored for the way you do business requirements Compliance framework and workflow Goals, modules, workflow, options requirements Months or Years Weeks or Months Because hosted solutions are share resources across many customers, they are more economical