Let’s compare record collections
A common theme emerging from all our recent skilled person work relates to records. In particular: what proportionate record keeping looks like. Whether it is small firms not recording decisions or larger firms who can’t keep a grip on the volume of records they create the issue presents in all of our review work.
We want you to challenge yourself on the records relating to your role. Are you capturing information in a structured and secure way that allows your decision to be repeated perhaps years down the line? Some examples from our work:
Formal committees: Committee minutes should show the discussion and challenge from the meeting. It should clearly rationalise why a decision was made (what risks were known, what mitigants were in place, why the decision was considered ok)
Escalations and decisions: Records should be very clear on what is being escalated and why, including the desired actions to be taken. Most firms get this bit. But the record of the decision, the rationale for the decision and who made it is often lacking
Customer contact: Meeting memos should fully outline the conversations held with a particular focus on risk factors and any explanatory / mitigating points
KYC forms: need to contain narrative explanations of why decisions were made. You can’t just assume because you have another document on file (e.g. a bank statement) that that is sufficient to explain a decision – you need qualitative descriptions as to what the evidence tells you and why you deem it to be OK or not
Flow: Records around throughput are also really important to support meaningful MI – this might include cases completed, time to complete, overdue cases (aged analysis) – all of this needs to be split by type of case, Analyst etc.
Sensitive / personal information: this blog isn’t about data protection obligations – they need to be complied with and can be complex. But it’s about your decision making processes
You also need to think about where you keep your records. So often we see bits of the above buried in e-mail chains. Strategic and dedicated CRM solutions or management information systems are clearly preferable, but practically it is often end-user computing solutions (word and pdf. documents, spreadsheets, shared drives) that are used. Records being saved on local devices or in inboxes are always harder to recover when needed.
There is no upper limit on the level of detail, comprehension and quality of records you can keep. But there definitely is a lower limit on what needs to be recorded. Whilst it may feel burdensome at the time – maintaining good records can be a game changer if you’re subject to a future regulatory review. Even if your firm doesn’t have measures in place for consistent and quality records - protect yourself and your own reputation / credibility by ensuring your records are up to scratch. If you’re a decision maker or regulatory role holder you need to be taking a greater focus on how records are managed more strategically across your organisation.
Small(er) firms have a tendency to think that because of their size they don’t need to keep as many records. This is rarely the case.
We can help you find that sweet spot between poor records and administrative overload. Get in touch to discuss.
