Is your firm ready for November 14th?
To help firms prepare for the FSA mobile phone recording requirement that goes into effect on 14 November 2011, we hosted a breakfast seminar on July 6 at the Langham Hotel, London to discuss hedge fund technology, specifically archiving, mobile voice recording and disaster recovery.
Our panel of experts included: Simon Eyre, Service Director at Eze Castle Integration, Robert Powell, Director of Compliance at Global Relay, and Phillip Chapple, Executive Director at KB Associates.
The removal of the current exception (COBS 11.86R (1)) to mobile phones and other handheld electronic communications devices comes into effect November 14 after concerns were raised by stakeholders over the difficulties they face in recording communication on private mobile devices.
Effective from November 14, the FSA will require all regulated firms to meet the following mobile recording requirements:
- Record all ‘relevant’ conversations on firm- issued mobiles;
- Store mobile recording for 6 months;
- Take ‘reasonable steps’ to prevent ‘relevant’ conversations on unrecorded private mobiles;
- Comply with local recording regulations when users are oversea;
- Take ‘reasonable steps’ to record when staff are overseas; and
- Record all mobile communication methods.
You can read the FSA’s official statement on taping of mobile phones here.
Let’s have a look at the hot topics discussed at our recent breakfast seminar:
Given the fast approaching deadline of November for PS10/17, what technologies are people in the industry beginning to use for mobile voice recording?
Technologies seem to be prevailing; there are three main technologies many firms are using for mobile voice recording:
- Cloud based redirect;
- Carrier based recording; and
- Network carrier conferencing (SIP/ISDN) - The network conferencing approach allows a mobile solution to a mobile problem, with minimal impact in call or data costs and no requirement to purchase new, unaudited hardware.
What features should a firm look for in a disaster recovery system?
There are six key features every firm should look for in a disaster recovery system:
- Prioritisation of Systems;
- Dedicated Resources;
- Cost vs. Functionality;
- Managed Solutions with 24x7x365 support;
- Quarterly Testing; and
- Proven Technology.
How do investors view disaster recovery and business continuity planning as part of their due diligence process?
- Investors are looking for “appropriate” solutions for each firm.
- The two main angles are solutions which work for the type of firm and leave no “gaps,” plus appropriate in terms of cost to ensure business is viable.
- Security of solutions is key (i.e. shared clouds and wireless solutions an issue).
- Investors have done their homework on solutions and expect managers to have done the same.
- Lack of appropriate BCP is a very real business risk many funds do fail on this, although due to lack of investor feedback it is not always obvious.
For further information and useful resources, please visit:
- Hedge Fund Technology: A Look at Archiving, Mobile Voice Recording and Disaster Recovery resource page
- Article by Travers Smith LLP looking at “Telephone taping: removal of the mobile phone exemption”
Also, don't forget to come back on Thursday, July 21, for Part 2 of our series on PS10/17.
Photo Source: iStock
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