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IIROC (IDA Canada) Messaging Compliance
IIROC Compliance Archiving & Monitoring
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As the leading hosted archiving provider for firms regulated by IIROC (Investment Industry Regulatory Organization of Canada), Global Relay specifically engineered its Message Archiver, Compliance Reviewer, Message Converter and IM Interpreter to provide a total compliance archiving & monitoring solution for firms subject to IDA By-law 29.7 and UMIR Policy 7.1 in connection with electronic communications with the public such as email, attachments, IM (AOL, MSN, Yahoo, LCS etc.) and Bloomberg®:
- Recordkeeping
- Supervision
- Audits
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Recordkeeping
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The Message Archiver, Global Relay's message archiving and compliance system, captures and archives an authentic and complete record of all electronic business communications in a secure but easily accessible offsite storage system. Compliance features include:
- Message Capture of email, attachments, IM & Bloomberg
- Archives messages for 5 year IDA term (or as defined by deletion policies)
- Access includes web-based instant access for all employees to their messages
- Tamperproof protection of data on dedicated WORM (Write Once, Read Many)
- Offsite, mirrored, single instance storage in East/West Coast Data Centres
- Indexes & serializes messages, Bcc & Distribution Lists, metadata & audit trails
- Search & retrieval of any message in seconds using Google-like search engines
- Security & encryption of systems, networks & messages
- Migration of legacy data (.pst files, backup tapes) & to archive with new messages
- Retention Term flexibility for Litigation Holds & IDA investigations
How does the Message Archiver work? All email, attachments, Bloomberg and IM and are securely captured and centrally unified together with imported legacy email and .pst files, in Global Relay's Message Archiver for rapid online search, retrieval & monitoring. With secure web-based access and real-time indexing powered by search engine technology, every employee and Compliance Officer has the ability to find any current or historical message in seconds. Read More »
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Supervision
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The Compliance Reviewer, Global Relay's monitoring system, provides Investment Dealers with a turn-key, flexible, online supervisory system with advanced monitoring, filtering and eDiscovery features enabling enforcement of your firm's email & IM policies for compliance, proper usage and corporate governance. Compliance features include:
- Scan & Monitor email, attachments, IM & Bloomberg from online Archiver
- Content Filtering with company-defined rules to identify prohibited content
- Advanced Analysis with Boolean logic, criteria lists, proximities & action alerts
- Random Sampling of each rep's messages customized by percentage & user
- Keyword Search results are highlighted within the message for quick discovery
- Full Review of messages & attachments, or bulk review of headers only
- Reviewer approval, rejection, escalation based on action icons & defined notes
- Multi-tiered Review structure for review escalation to Super Reviewers
- Wizard Commands for pre-defined, single-click compliance using folders, flags, priorities & labels
- Exclude Words, phrases or email accounts (e.g. disclaimers, attorney-client privileged mail, newsletters) from Flagging Rules
- Access Rights of authorized Reviewers governed by customized security rules
- Notifications of compliance violations by email or IM
- Audit Trail with detailed time history of reviews and related actions taken
- Web-based Control Center to modify surveillance & monitoring procedures
How does the Compliance Reviewer work? Using powerful search engines, the Compliance Reviewer is able to retrieve your firm's messages from the Message Archiver and apply easy-to-use, company-defined filters and Wizard Commands for efficient review and monitoring of all archived email, IM, and Bloomberg messages. Messages of any user are analyzed on import and flagged for review if violations are detected as follows:
- real time filtering for keyword or phrase violations (start-up list provided)
- specific query using flexible search criteria
- advanced rule-based keyword & phrase proximity analysis
- random sampling (by User, User Group, or firm-wide, using percentages).
Read More »
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Audit Controls
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Global Relay's Message Archiver & Compliance Reviewer Audit Tools are designed to facilitate efficient responses to regulatory audits and evidentiary requests. Global Relay has successfully assisted hundreds of IIROC, SEC, and FINRA regulated firms during their audits and regulatory investigations. Currently, Global Relay participates in approximately 3 to 6 customer audits per week.
- Search & retrieval of any message in seconds using Google-like search engine
- Audit Request response within minutes using online search and eDiscovery tools
- Statistics & reporting on Compliance Officer reviews & related actions taken
- Retention Term flexibility for Litigation Holds & anticipated investigations
- Legal Compliance in-house specialists to assist during audits
- Case Management via folder system with shared folders (e.g. external attorney review)
How do Global Relay's Audit Tools assist with an Audit? Global Relay provides flexible and efficient methods to produce records according to the specific criteria of the audit request. Messages are made readily available for examination either by:
1. Online review of messages via an "auditor account" in Message Archiver
- create online search parameters based on Audit request
- restrict access to the exact scope of the audit (by date, user, subject etc.)
- assign Auditors temporary online review privileges
- block attorney-client privileged, personal or restricted messages
- generate an automatic audit trail of Auditor's review (ie: audit the Auditor!)
- side benefit of data no longer in Auditor's possession once audit is complete
2. Compilation of data for delivery to IDA
- fast discovery, consolidation and organization of data for export & delivery
- compile requested information on regulator-qualified media such as DVD or CD
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Frequently Asked Questions
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What are the email & IM Compliance Requirements for IIROC?
In connection with electronic communications under IDA By-law 29.7 and UMIR Policy 7.1,Rule 10.11, firms must:
- monitor electronic communications using a system designed to detect compliance violations (UMIR Policy 7.1 );
- educate and train employees on procedures governing public electronic correspondence;
- maintain an audit trail and record of supervisory reviews (to be retained for 5 years under UMIR Policy 7.1);
- evaluate and monitor supervisory procedures to ensure compliance;
- retain all electronic advertisements, sales literature for 3 years, and correspondence with the public for 5 years;
- store & verify accuracy of all electronic order information (UMIR Policy 7.1, Rule 10.11);
- index & store all electronic records;
- make readily accessible all stored business-related electronic communications prepared for clients, and all records of supervisory reviews for inspection by the IDA.
What is the significance of these rules?
Regulators are no longer tolerating inadequate recordkeeping and supervision of a firm's electronic communications. The IDA has adopted mandatory requirements designed to protect investors from misrepresentation and fraud via electronic communications and to prevent record tampering. Amendments to IDA By-law 29.7 impose requirements on firms regarding both archiving, and monitoring and post-review of electronic advertisements, sales literature and correspondence for clients. The Internet and email are incorporated in the By-law's definition of "electronic correspondence." The Universal Market Integrity Rules for Canadian Marketplaces UMIR Policy 7.1 also requires a compliance supervision and preservation system to be put in place.
Who must comply?
Generally, this legislation is applicable to all persons engaged in trading or acting as a dealer, including investment dealer firms and registered representatives that fall under the jurisdiction of the IDA.
What are the repercussions of non-compliance?
Increasingly, regulatory investigations focus on business records and supervision of the same. Firms cannot afford to have a casual attitude toward email supervision and record management, as the repercussions of non-compliance include internal and/or regulatory disciplinary actions, costly penalties, civil liability, damaged corporate reputation, loss of goodwill and clients.
Where can this Legislation be found?
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Chicago Stock Exchange selected Global Relay's robust Compliance Archiving & Monitoring services to deliver secure, scalable, high-performance archiving & monitoring to its employees & Member Firms.
Canaccord Capital & Canaccord Adams, with IDA, FINRA and LSE Memberships, chose Global Relay to deliver email, instant messaging and Bloomberg Archiving, Compliance and Continuity to 2000+ employees spanning three continents.
Westwind Partners uses Global Relay to outsource all their email compliance under the IDA, FINRA and FSA/LSE.
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