When I joined FinTrU in May 2020, I began working on Client Outreach. This was FinTrUs first Technology solution and I was the first to join the team. Work began in research to understand the problems, and it is currently being onboarded as a KYC solution by one of the worlds leading investment banks.
The journey of how it got from there to here, is documented below.
What is Client Outreach?
When new legislation comes into effect, financial institutions need to ensure compliance, and therefore need to obtain the required information from clients. This involves "reaching out" to clients to request documentation or signatures.
The Client Outreach process currently looks like this:
1. Collate a list of clients potentially affected by the new legislation.
2. Identify the data / documentation that is required to ensure the client is compliant.
3. Verify the contact information held for the client is correct (check databases).
4. Reach client by email.
5. Track client responses (currently done manually using spreadsheets).
6. Send chaser emails to follow up on non-responsive clients.
7. Check the data / documentation provided by clients (reviewed by project manager).
8. Ensure every interaction and correspondence with a client is documented.
✅ Automate tracking of all activity to remove need to manually update tracker.
✅ See all information related to a case in one place.
✅ Provide one central tool to manage workload, from assigning work to completing cases.
IHS Markit - https://ihsmarkit.com/index.html
Bloomberg Entity Exchange - https://www.bloomberg.com/company/press/entityexchange/
FrontApp - https://frontapp.com/
Campaign monitor- https://www.campaignmonitor.com/
Leverage automation and outsourcing with regards to per-client adherence.
Outreach-oriented regulatory tools and services can facilitate the terms-adherence process across a dealer's client base. Capabilities that include furnishing a pre-existing database of regulatory-relevant client representatives; providing centralised tracking for outreach personnel; sending auto-generated follow-up emails to unresponsive clients; generating rules-based system prompts for clients to upload specified types of supporting materials, where needed; and provisioning of customisable, client classification-specific terms to be sent out form elements of an effective terms-repapering solution. Additional features including e-signature capability and centralised client query entry enhance the client experience, and further support terms adherence.
Provide transparency to clients.
Some clients will use this as an opportunity to re-open the entire customer agreement. However, to meet the deadline, provide your clients with transparency into what is required to achieve compliance with the Directive, and why specific terms must be updated.
Adopt a phased approach to terms-adherence.
Rather than outreaching to all clients in one attempt, begin the outreach for terms adherence in waves of clients. The inputs for client segregation into waves of outreach will vary per dealer, and are likely to include considerations such as revenue-generation impact of the client, existing client classification, and the likelihood of a particular client segment wanting to negotiate away from stock terms.
Terms-repapering will be a significant undertaking for all investment firms subject to MiFID II adherence, more so for dealers where the client base is substantial. Firms need the right technological tools and appropriate client data as well as client contacts in place to expedite this task. This, coupled with well-trained staff and a carefully-planned approach, will help to lighten the load.
Searching FinTrU Blogs for more info on Outreach
It is essential that firms are conducting client contact, discussion and negotiation in line with TCF and conduct risk obligations. The FCA expects firms to keep their customers appropriately informed about the risks and impact of the LIBOR transition on existing and new financial products and services they offer or distribute.
A robust, coordinated and appropriately resourced client outreach strategy will be key in being able to meet these regulatory expectations. Firms must communicate information to customers in a manner that is clear, fair and not misleading. In practice this means:
clearly describing LIBOR discontinuation risks and impacts for existing LIBOR-linked products
where new or alternative product options are presented for existing LIBOR-referencing contracts, the range of options should be reasonable and fairly presented, including the benefits, costs and risks
not disguising, reducing or hiding relevant information
considering the knowledge and experience of the intended audience
Client engagement and clear presentation of relevant information should be initiated as early as possible to raise transition awareness and educate on implications for both new and existing contracts. This will also allow clients to make informed decisions concerning affected products, the risks to which they may be exposed and new products or solutions that may suit their needs.
Where frontline staff lack relevant knowledge or awareness, poor client outreach outcomes will be produced. This in turn may lead to situations where clients are given conflicting messages from different parts of the business. Internal communications strategies should allow sufficient knowledge of the LIBOR transition to filter down to all impacted functions. This may require the roll-out of training programmes and the creation of internal escalation pathways, knowledge libraries and operational playbooks to support efficient and accurate responses to client queries.
Execution of outreach
Client communications linked to the LIBOR transition should be accurately informed and executed in a clear and consistent manner. Robust systems solutions that allow for accurate and timely tracking of all interactions should also be in place. This should include provision for recording all LIBOR-related client communications - particularly important in circumstances where there are multiple open channels of communication between the firm’s stakeholders and the client. It is also of paramount importance that interactions are strictly informative to clients and do not stray across the line into providing advice or recommendations.
While the FCA is strongly encouraging alignment across the industry, regulated firms may reasonably adopt different approaches to what they need to do and by when. It is also more likely that unregulated counterparties not directly subject to any regulatory pressure to renegotiate LIBOR-linked contracts may demonstrate more reluctance, or a greater lack of urgency, to engage.
Client outreach and the subsequent contractual renegotiation process will be complex. Given the number of different relationships that a firm may have with the same client/counterparty (including across multiple products), a single, coordinated approach to contacting each client/counterparty is optimal but may not be possible.
The consequences of a lack of legislative underpinning is that some counterparties or clients may be quicker off the mark and expect answers sooner than a sellside firm is able to provide them. A slow response could therefore affect a firm’s competitive position in the market.
The trigger for the demise of LIBOR was pulled over three years ago and with the end-2021 date now firmly in sight it is incumbent upon stakeholders to heighten their readiness and develop robust plans so that timely, compliant solutions can be agreed and implemented. The FCA is stepping up engagement with firms and has warned that if sufficient progress has not been made by mid-2020, the Bank of England will consider recourse to supervisory tools to ensure a smooth transition.
Regulations to adhere to (theres more):
Efficiency of Outreach (efficiency)
1. Golden source reference data 2. Re-usable templates and questionnaires tailored to fit your internal policy 3. Quality assurance process helps ensure that the documents returned by clients are responsive to the request that was sent
Some findings from creating an account and having a nosey about....Campaign Monitor leads you along a streamlined process and add additional functionality where required to send a templated email to a pre-defined list of contacts. The benefits of campaign monitor:Can create lists/folders of contacts and segregate- also nice overview of what you are doing at all times before proceeding Workflow- can create user journeys that will be automated with conditions appliedPick a template and build an email Integrate apps for assistanceTransactional emails (required domain to do this)Adding contacts ( Subscribers in CM)Steps:Create new listEnter email, name, ageSelect category for these pieces of dataSavedShown as below:You can also create segments to divide the lists into groups of people. There is a bunch of features connected to adding a contact and what you can do with the lists and segments such as automation triggersFor example:Choose this trigger to automatically send emails to new subscribers or customers. The journey you've created will be triggered to send when someone subscribes to your list through a signup form, or is added individually to a list through an API call.Beyond a standard welcome email it could be used, for example, to deliver a training course over a few months, guide potential customers through a product trial, or to send out chapters of an e-book.New contacts added to the system (by any means) could automatically be emailed to welcome and start the process with a set of pre-defined steps (the usual method of initial contact but automated) Throughout the process this can be automated by notifying the supervisor and user at all steps whats next to complete in the process- my understanding is that there as various processes and workflows involved and this some of the process could be automated by triggers related to lists of contacts - list of users would have the same template applied and email sent. AutomationSuppression lists e.g. Email addresses on the suppression list can't be accidentally imported or added to your regular subscriber lists. Whenever you add new subscribers, we'll automatically check it against this list to ensure any suppressed subscribers are not added.Validation when deleting contactsJust a nice safety net when contacts are so importantCampaignsTwo types of campaigns available- regular and A/B testingmerge fields - first name into subject lineusing peronaliationcan reply to another email address (good question to ask)TemplatesChoose a template by clicking on itBuild the email using the template- nice wee simple builder:Shown in desktop and mobileLots of different settings and fallbacks for when the devices dont support the templates ect.Schedule the delivery of the email and reminder of the email its being sent toConfirmation of the deliveryReport showing any bounce back and if the email has been opened ect.Weekly campaign report sent to emails- open rate, click rate, bounce rate and unsubscribed rate.Creating JourneysAutomated journeys for a specific list important to work out the different workflows in research for automated tasksAutomating the different steps for the journey based on conditions e.g. new user, new legislation, email bounced back, no reply, remindersConditions e.g if an email bounces back then trigger notification Flow rules - if yes -do this, if no do something elseSmart tranactional emailsTransactional emails are triggered by your own site or app, typically in response to a user's action, such as an order confirmation or a plan renewal. They are some of the most valuable emails a company sends, but usually aren't measured or optimized. .Integration from other appsNot sure if this would ever be needed but to document:Examples:google analyticssalesforcewoo commerce
Visual automations - rule sets that allow you to build up a user flow for email campaigns
Customise a subscribers path based on their actions (contact)
Send well-timed, targeted content to the humans in your audience
Always know whats next for your subscriber- notifications
Segment your audience based on their customer journey
Context at a glance- quick look at your visual automation
Progress bar taking the user through the journey to let them know where they are in the process at all times, could also be used as a back bar...1 > 2 > 3
Graphical view of contacts (this is a marketing tool so its growth indicator is dependant on how many people are subscribing)
Templates- email builder - can edit content and upload content also before choosing contacts to send to, preview before sending, ability to download template- rearrange the content of it
Funnels- visual automations by building custom paths for your funnels by connecting events, actions and conditions. when joined together, these elements create your subscribers journey in one easy-to-understand and totally customisable process.
Funnels- events, actions and conditions
A full set up user journey (imagine a user flow)
Events - jump to here when a -tag added, tag removed, date occurs, custom field
Action- add the subscriber to a - email sequence, add or remove tag, delay, move contact, set custom field
Condition- if the subscriber has a- tag or custom field
Simple automation rules
What is important for an Outreach manager to see?
Who are Outreach Managers? Are they the only ones getting data from reports?
Outreach managers are the Supervisor's counterparts on the client side.
They are interested in the general progress of the Outreach, however they are not the only party interested in the analytics. Depending on the size and complexity of the project, there can be a large number of stakeholders who receive daily or weekly updates.
What kind of information is an outreach manager/client stakeholder looking for?
Outreach managers are interested to know if the targets that they set in their agreement with the Outreach team are being met and that there is visible weekly or daily progress in the completion of cases.
What information makes them take action?
If a case is stuck at a specific stage within the outreach is starts to trigger conversations between the Supervisor and relevant stakeholders about what can be done to help push the case foreword.
If the rate of progress on the project is drastically different from one week/day to the next, then this will trigger discussions around why that is and what can be done to fix it.
What kind of data do supervisors report to the Outreach Manager?
Where does the data currently come from?
The data for the reports currently comes from the trackers in Sharepoint that the team puts together;
As Outreach is part of the wider KYC process, the tracker contains columns that have data for the other departments involved with KYC as well;
Trackers can be complex and have hundreds of columns. Usually a tracker it put together at the beginning of a project and can take time to get right and make sure that they are capturing all the data that all of the other departments might need for their work.
The trackers are updated manually, therefore sometimes the data that they contain is not accurate. In order to create the reports, the data is taken at a specific cut off point during the day or week (eg: 5 pm on a Friday). If the employees haven't updated their case statuses by that time, then the report data will be inaccurate.
Another issues with the data is that, even before the project is started, the data that the client provides for the outreach might be inaccurate (eg: information is invalid or outreach e-mails sent to the client end up in their quarantine inbox)
How often do reports go out to managers? What do those reports say?
The frequency of reports that goes out to the client varies depending on the number of stakeholders involved in the project, the complexity and risk of the information requested.
Sometimes ad-hoc reports are requested, based on data from the tracker.
Monthly reports are used to check the initial Service Level Agreement and to see if the project is meeting its milestones for completion.
More frequent reports (daily or weekly) are used to check the progression of the cases through the process. These reports are used to identify cases that have been stalling and trigger conversations around what kind of actions can be taken in order to move the cases along the process.
How is this data currently visualised? Are there ways to make this more efficient?
The data in the reports is currently communicated via e-mail. One e-mail is sent out to all of the stakeholders, which contains the same data for everyone.
A highlight is included in the body of the e-mail, which contain the most important numbers of the week. More detailed metrics are included in an attached powerpoint.
Metrics that are included in the highlight:
The number of cases that have been completed on the week of the report
The % of the cases that have been completed within the day/week compared to the previous day
Trends showing forecasted completion rates for the following day/week, based on the current rate of completion
The number of cases currently sitting within all of the statuses of the outreach
Comments can also be added to explain any anomalies within the data
How complex is this data to visualise?
Some reports, like the progress reports, are easy to create and run in-house. However, for more complex data that it outsourced to external contractors;
Complex reports take into account the metrics needed for the entire KYC process, not just the Outreach part of the process;
Different teams within the KYC process use different metrics to track their progress.
What is "ageing" and how would we expect to see that reflected in Outreach?
"Ageing" refers to the length of time it takes a case to go from being handed to the case worker to being forwarded to another department;
Supervisors track the ageing of the case to make sure the project is on track and to help diagnose any issues within the process. Seeing which cases are not progressing can help them to initiate conversations (whether internal or external) to get the case moving along;
Ageing of cases is also relevant for the wider KYC process, as the documents that are acquired during the Outreach process will be used by other departments too. Therefore, a supervisor will report on the ageing of cases to other departments as well.
Weekly reports are sent out showing the progress of the cases. One participant mentioned that they break down cases by age within the report (1-10 days, 10-20 days, 20-30 days).
Other interesting observations
In addition to understanding the progress of the outreach, metrics are also used to understand team and individual performance. This is usually highlighted in a monthly report to the stakeholders as evidence that the Outreach team is meeting the commitments in their Service Level Agreement;
Supervisors use individual case worker metrics to start conversations on individual performance with their direct reports. These metrics mainly relate to how many cases the case worker has made progress on in a day and if they are falling behind their set targets.
The Outreach process can be unpredictable and a case worker's productivity and the project's progress can depend on a number of factors, which are outside of the individual case worker's control. Metrics can be used to point out where cases the case worker is working on are stagnating, but they don't show the cause of it. Supervisors will frequently have talks with their staff on their individual metrics, in order to figure out exactly what actions they need to take to move the project forward.