Audit-proof supervision of post archival content and electronic
communications for IBM ECM repositories
April 25, 2013
© 2013 IBM Corporation
For Internal Distribution Only
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This is a Must Have Item for Financial Services
• FINRA expects a firm to have supervisory policies and procedures to monitor all
electronic communications technology used by the firm and its associated persons to
conduct the firm’s business.
• As required by previous SEC, NASD, and NYSE rules, firms must ensure that they
have processes in place to keep records of these communications to prove in an audit
that the required supervision was consistently being accomplished.
© 2009 IBM Corporation
© 2013 IBM Corporation
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Industry Challenges
Require companies to Establish and Maintain systems to Supervise Activities and
Electronic Communications. Failure to do so can result in hefty fines.
 Ex: ING Firms Fined for Review Failure. In February 2013, FINRA fined five ING
affiliates $1.2 million for failing to capture millions of emails, and for failing to
review nearly six million messages flagged by their review software.
 Ex: Metlife fined $1.2 Million because brokers withheld emails and concealed
evidence or "red flags" of misconduct without detection by the firm
Internal Business Challenges:
 Multiple archive systems and un-integrated tools
 Unnecessary time and resources used reviewing false positives and duplicates
 All changes in lists not being versioned or captured
 Struggle completing regulatory audits
 Manual process for escalation and review
© 2009 IBM
Corporation
 Restricting
supervision
process to specific people
 Foreign language review
© 2013 IBM Corporation
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iZon Target Market
Financial Services Sector:

Capital Markets, Broker Dealers, Hedge Funds

Banking

Insurance
Line of Business:

Compliance, Legal, Risk Management
Decision Makers:

Chief Compliance and Risk Officers, General Council, CIO
Decision Influencers:

President, CEO, CFO, Legal, Operations,

IT Business Analyst
Firm Size:
 Will support any firm that has a Compliance and Risk Management
requirements
© 2009 IBM Corporation
© 2013 IBM Corporation
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Solution Introduction
iZon Compliance provides a single integrated supervisory solution for post-archival
content and electronic communications
Built on the IBM ECM platform
Easy to use graphical dashboards, with customizable desktop views that can
be defined by user roles:

Supervisor

Manager

Legal
Create Keyword Groups and Lists

Versioned and Secured

Leverages meaning based and lexicon search technologies

Provides fewer false positives

Group level rules for: Distribution, Restrictions, Exclusions, and Random
Sampling

© 2009 IBM Corporation
Records
– Date and Time, Type and Person making Changes to any
group or list
© 2013 IBM Corporation
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Unique Capabilities
Detail audit trail of every action taken associated with every flagged item
 “Flagged” content can participate in workflows based on reason codes
 Eliminating a manual process for escalation and review
Discussion threads linked to item through a tab through a tab in user interface
Custom warnings and notifications that are easily generated and delivered to
appropriate parties with a click of the mouse
 Generates a PDF letter and auto adds process information with your specific
legal language
Preview items prior to opening in native application
 Secure Microsoft language translation (optional)
Bulk review capability
 Ability to select multiple items in the review queue and mark as reviewed
Supports
ad-hoc
searching through eDiscovery providing access to all
© 2009
IBM Corporation
archived content
© 2013 IBM Corporation
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IBM Software Pull Through
iZon Compliance requires four IBM ECM products to operate:
 IBM Content Collector
 IBM eDiscovery Manager
 IBM eDiscovery Analyzer
 Repository choice of CM8 or P8
iZon Compliance with the IBM software stack and core implementation services has
a starting point of $200K for managing up to 50 registered representative email
boxes.
© 2009 IBM Corporation
© 2013 IBM Corporation
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iZon Architecture

Built on Microsoft .NET Framework and
MS SQL

Fully XML based design and
implementation

Web 2.0 Features

Full HTML/HTTP/HTTPS Support

Web Services Support

Proven Multi-Tiered Architecture for
DMZ/Scalable Deployments

AES/DES/SSL/MDAC5 secured system

AJAX based UI for interactive web
interface
© 2009 IBM Corporation
© 2013 IBM Corporation
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Clients
Georgia Based Large Financial Services Company:
 The company offers term life insurance coverage to some 4 million customers in the
US and Canada. It also serves as a broker of debt consolidation loans, investment
and savings products, and long term care insurance through other underwriters.
 Approximately 40,000 Licensed Securities Representatives Requiring Supervision
 Was using Autonomy – but in a head-to-head review of the same pool of messages
over 15 days, iZon Compliance flagged about 85% fewer messages. However, the
iZon Compliance system identified 25% more violations.
International Bank with New York Operations:
 U.S. and international private banking services as well as a full range of securities and
insurance products through its brokerage subsidiary.
 Was an existing FileNet shop using manual processes for flagging and reviewing
emails. Which we automated - greatly improving the efficiency and accuracy of the
review process.
© 2009 IBM Corporation
© 2013 IBM Corporation
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$$ Call to Action $$
Working together to develop local OI campaigns – contact Pete
Current campaign in place to generate leads (tactic code: 101CB2CE)
Demos to compliance officers = key to success and displacing what they “have”
Low hanging fruit

Existing IBM ECM install base (likely don’t have ECM licenses in
Compliance/Legal)

All Autonomy, (Zantaz, CA Message Manager, and Iron Mountain) Accounts

Symantec and EMC Accounts
© 2009 IBM Corporation
© 2013 IBM Corporation
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Conversation Starters
How are you accomplishing FINRA required electronic message supervision today?





Is this manual or are you using software?
If software, what vendor are you using and how licensed?
Own or term licensed?
If term – when does term expire?
If owned – when is the maintenance renewal date?
Are you prepared today to pass a FINRA audit regarding electronic communications,
monitoring and supervision?
How many registered reps are you responsible for monitoring and supervising their
electronic communications?
How many employees do you have focused on monitoring your electronic
communications
as required by FINRA?
© 2009 IBM Corporation
© 2013 IBM Corporation
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Contact
 Headquartered in New York, NY – will go where the deals are!
 Significant ECM BPM Experience - working and selling IBM ECM since 1996
 AST can compete with the “big boys”
 www.izoncompliance.com
AST Contacts
Peter Ettinger
peterettinger@astworld.com
(917) 284-3886
Marjory Dury
mdury@astworld.com
(212) 682-4160
IBM Contact
Dianne O’connor-Miele
Channel Sales Manager, Software Group, ECM
dmoconno@us.ibm.com
(914)806-2504
© 2009 IBM Corporation
Thank you for your time today.
Questions?
© 2013 IBM Corporation
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