E-mail & Instant Messenger(IM)

During a normal audit the SEC requests approximately 33% to 50% of the email from the Adviser for a specified period of time, as generally required by the 37-page SEC Pre-Exam Questionnaire.

The SEC’s cites that traditional email systems (Outlook, Lotus Notes, etc.) fail to place any internal control structure around the indexing, sorting and filing of email.

Therefore, the new risk-based examination requires the SEC to conduct an extensive review of email in light of the risks associated with lost, misplaced, misfiled, deleted or altered correspondence.

TurboCompliance^SM re-engineered the processing of email and IM by installing a comprehensive internal control structure around the entire process, including automatically:

• Indexing, Sorting and Filing email into the appropriate Correspondence and, if appropriate, the Complaint File
• Monitoring outgoing communications for incompliant words and phrases as well as incoming messages which rise to the level of a complaint
• Detecting action items, preventing incompliance
• Reporting up the chain of command
• Documenting any incompliance on the supervised person’s Compliance ScoreCard^SM
• Sanctioning the supervised person per the CCO’s rules, formulas or schedules
• Conducting Interim Audits
• Preparing the Annual Review required by Rule 206(4)-7.