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Compliance Software Employee Conflicts of Interest

6 Achievable Steps To An Agile Compliance Program

Agile has made the jump from the world of software development to the world of compliance. Join us for a recap of our recent webinars on the subject and actionable advice on how to make the jump yourself

Recently, StarCompliance—in conjunction with Quantum Of Value, an Agile methodology consultancy—hosted a webinar on how to apply the Agile methodology to a firm’s compliance program. To get StarBlog readers and webinar attendees ready, two weeks ago in this space we published a primer blog on the Agile process—how it evolved and what it’s all about from a high-level perspective.

In today’s StarBlog, we’re offering a recap of these webinars—hitting the highlights and offering actionable advice for applying this game-changing project management process to your compliance program. In particular, we’re going to look at a practical example of applying Agile to a situation every compliance department has to face on a regular basis, one that cries out for the kinds of efficiencies Agile can deliver: onboarding a new employee.

Here’s a typical sequence of events and tasks that compliance must iterate through when there’s a new hire at an enterprise financial firm, followed by a step-by-step of how the Agile methodology could help:

  • The new employee record is received via an HR feed into your compliance software.
  • The compliance team reviews the new employee from a functional, regional, and risk perspective.
  • The new employee may be placed in specific user groups based on the above.
  • The new employee must be activated.
  • The new employee must complete initial certification, which typically includes: links to compliance policies and procedures; attestation of understanding of policies and procedures; declaration of broker accounts for employees and household members; and current holdings.
  • The compliance team must review all initial information, which must be supplied within a certain period of joining the firm.
  • The new employee and compliance must gain consent from brokers to supply duplicate personal trading details.
  • Compliance must ensure the new employee receives adequate training and maintain detailed training records.

“Agile is an umbrella term,” says Agile expert Allison Bacher, “a catchall for describing lots of different practices, frameworks, tools, and techniques that are all in some way iterative, collaborative, and incremental. What that means is, whatever it is we’re trying to do we break it down into smaller components, prioritize those components, and deliver them in a very collaborative and uncluttered way.”

Collaborative and uncluttered in this sense means the group of people you have working on a particular sprint (find a glossary of Agile terms here) is working only on tasks related to that particular sprint. And it’s understood that no team members will be pulled away or asked to do any work that’s not associated with the current sprint. They are ring-fenced, in other words, from any and all distractions. “Everybody’s there, they’re dedicated, and they’re ready. This alone reduces a lot of waste,” adds Bacher.

“Across our client base, particularly in financial services, we’ve got clients who say they’ve improved their time to market by at least 40%,” says Bacher, “a genuine 40% reduction in time-to-market. How did they do that? Not by running faster, but by prioritizing what they really need to do. So it’s about working smarter, not harder or faster. It’s about focusing on the must-haves, the really essential things.”

Define your goals is exactly what it sounds like. Know precisely what it is you want to deliver. Map the user journey means create a visual representation of how your customers or stakeholders will interact with your product. In the case of our new employee onboarding example, that product is getting her efficiently and comprehensively through the above onboarding to-do list. “Journey mapping helps you better understand customer needs,” says Bacher. “It helps you see things from their point of view.”

In the Agile world, an item is ready when teams have all the information required to execute, test, and deploy the end deliverable. Done is when that deliverable meets governance and quality standards, and is releasable. Again, Bacher: “Ready means we don’t start something without a piece of key information, because then we do half a job. And done means done. Something can’t be part done. It either is or isn’t. Being Agile means being strict about all this. Governance is an integral part of the process.”

Applied to the new employee onboarding process, the checklist for completing initial certification includes: (1) completing an attestation of understanding of policies and procedures; (2) declaring broker accounts for employees and household members and; (3) reporting current holdings. Ready means both you and the new employee know exactly what she has to do, and that she has the tools required to do it. Done means having a way of making sure she did everything she had to do. That’s where the onboarding checklist comes in.

The board is a shared space for auditable planning, whether it’s a physical board in the office or an online board, like Trello or JIRA. The board is where Agile teams create and maintain their product backlogs. “To be clear,” says Bacher, “product backlog doesn’t mean you’re behind on something. It denotes all the things that need to be done. It offers transparency to everybody that’s in the sprint.”

On a Trello board, for example, a compliance officer may pick up gain consent from brokers to supply duplicate personal trading details as their particular to-do item. So now, everyone can see what that compliance officer is working on as it relates to bringing the new employee on board. There’s visibility, in other words. Once that task meets the definition of done, it goes into the done column on the Trello board. “The board helps you set your priorities,” says Bacher.

Sprints are timeboxes. In the world of software development, timeboxes are typically one to two weeks long. They don’t have to be, but the idea is to not get too far along the road of project completion, so that if there are adjustments to be made you don’t have to throw out months of hard work. Sprints should be short and focused. Sprints should also allow you to not just fix mistakes, but make improvements.

Bacher: “With Agile, we don’t put things out into the world that are broken because we catch problems in the sprint. At the end of every sprint we demo, basically, whatever it is we’ve been delivering. Who do we demo it to? Our stakeholders. That could be your CCO, legal counsel, any key people. They get to check their deliverable incrementally and we gather feedback, so if there’s anything we need to do differently—even if the whole thing is completely wrong—we’ve only wasted two weeks.”

In the case of employee onboarding we might ask, what else needs to be addressed? Did a certain part of the process take longer than expected? Did the employee struggle to understand her role in the onboarding process? Is there a part of the process that consistently causes pain for your team or new employees? If so, it may be time to take a step back and see where you can improve the process, which leads us to our final step.

The review is the team’s chance to, well, review what’s been delivered in the sprint. To sign off on what the stakeholder now has in her hands. To request changes for the next sprint. To make any adjustments to the backlog of upcoming requirements, if required. The retrospective is an opportunity for the team to think about how well it’s working—or isn’t working, as the case may be—in terms of people, relationships, processes, and tools, and to create a plan for improvements for the next sprint.

“We typically find there are small changes to make, not big ones,” says Bacher. “Our reviews and retrospectives are very transparent, like the rest of the Agile process. Everybody gets to give their feedback. We don’t get overly negative. We look at what worked well and say, we need to do more of that. We look at what didn’t work well and say, what do we need to do differently? Agile is about having a kind of fast-fail mindset. There’s always so much to get done, so we benefit from transparency. Everybody can see what’s been done and what’s still to be done, and anyone can jump in at any point. It’s actually quite a motivating way of working, whether you’re a software developer or a compliance officer.”