The capture and monitoring of text messaging has been one of the biggest and most frustrating compliance issues of 2024. We work with clients on capture solutions and for many, the costs are disproportionate to the institutional compliance risk. To simplify, we categorize firms into one of two groups.
The firm does not allow business communication texts.
This represents most firms, and compliance can implement without any additional cost:
- Require employees to sign-off an annual policy that specifies that he or she will not use text messaging for business.
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- These policies may simply be emailed to an employee’s corporate email asking to reply that they agree to comply. Their responses may go into a SharePoint or other compliance folder and kept as a record. Included in the policy is the requirement that if they do receive a business text, that the employee will forward to their corporate email account.
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- This policy does not require that software be loaded onto the employee’s phone, nor a second line set up on their device.
The firm allows some employees to text clients.
Firms that allow some employees to text will need to implement a capture solution.
- Employees who are allowed, should again annually agree to comply with the texting policies and only use authorized platforms. Other platforms / apps should be monitored by using a platform such as Microsoft’s Intune. In the screen shot, Intune shows whether an app such as WhatsApp has been downloaded to a device.
- As is often discussed on thread on the National Society of Compliance Professionals, compliance officers should not have access to personal texts, unless there is legitimate suspicion that someone is using a platform not consistent with compliance policies. This means that clients that are authorized to text need to have a 2nd business number as is provided by Movius or 1Global. This business number should be the only one listed on a registered brokers website, LinkedIn or other business social media site.
For more information or to setup a compliance consultation to review your text messaging compliance.
