Account Remediation Brochure
Data & Analytics
March 17, 2023DownloadsDownload Brochure
The Need for Account Remediation
Due to a reliance on legacy systems, outdated programming code and manual processes, normal course of business processing of investment accounts can result in errors to transactions and account balances. Often, these errors require a quantification of impact to each account. Companies need to remediate errors accurately and quickly for reputational and regulatory purposes.
Errors can surface from several sources including customer complaints or questions, internal quality control reviews, external audits, regulator reviews and whistleblowers. Unresolved issues can lead to violations of ERISA or other financial regulations and attract scrutiny and potential investigations from the DOJ, SEC and FINRA.
The Situation: Errors happen during normal business operations
- Legacy systems contain program code that has not been maintained or is leveraged for reasons outside its original use case. Even minor “bugs” in the program code can have a substantial impact on accounts that leverage it for daily updates.
- Manual processes increase the chance of mistakes during account maintenance processes. Without proper controls, mistakes can go unnoticed for a long period of time. These factors increase both the affected time and the number of accounts that require a correction.
The Problem: Providers are unable to timely correct accounts at scale
- Existing systems and processing protocols are manual and cannot perform calculations at the scale required for correcting errors that impact many accounts.
- Strong desire from within and outside the organization to correct accounts quickly and accurately to avoid further exposure to error. Independent calculations can meet regulatory and audit requirements.
Our Approach to Remediation
Our Data & Analytics practice deploys teams to build custom engines that can replay historical events specific to your investment product. These engines are capable of correcting errors at scale, returning results for thousands of accounts in minutes. The result is an accurate pro-forma account balance. We bridge the gaps across Legal, Compliance, IT and Operations to resolve the needs of all stakeholders.
Prior to a remediation engine build-out, we can deploy software engineers to identify the cause of the error and confirm the subsequent correction to the computer code was applied correctly. We help ensure clients have resolved the known error and advise on governance and control updates to prevent future occurrences of similar issues.
Our approach to remediation provides benefits to all parties interested in an accurate and timely resolution. Most importantly, this approach ensures account owners are accurately corrected. The approach benefits different functions within the organization including Legal, Compliance, IT and Operations.
Our priority is production of accurate results that ensure account owners are made whole. Accuracy is achieved through rigorous Quality Assurance programs that leverage dual coding approaches, selection of statistically valid samples for manual review, outlier testing and partnership with our Clients on their preferred approach to QA.
We understand the need for timely resolution and its deployment of technology allows organizations to correct accounts at scale. The sooner account owners are made whole, the sooner an organization can put the issue and the reputational risk that comes with it behind them.
The account remediation team provides documentation, account level proofs and access to source code to ensure our results are auditable.
Through its vast experience in financial services matters involving regulatory inquires, compliance questions and account remediation efforts, our team is well positioned to work with both internal and external counsel to ensure the correction process satisfies all legal requirements.
Our Approach to Software Code and Business Process Root Cause Analysis
Our approach to root cause identification relies on a diverse set of inputs, deploys numerous approaches to testing and results in identification of issues and errors along with recommendations for addressing current gaps and process improvements moving forward.
Internal policies and procedures
Functional and technical specifications
QA testing and results
Define expected outcomes and run samples to confirm expected behavior
|Assessment of an application’s ability to achieve stated purpose
|Source Code Review
Identify critical portions of code and review for confirmation of stated functionality
|Detailed examples of issues and errors discovered
|Application Database and Data Dictionaries
|Analysis of Systems
Assessment of viability given expected use case and processing load
|Policy, procedure and process recommendations
|Hardware and System Specifications
Test for data integrity, applicability of data model and identification of gaps in required information
|Data security, audit history and governance recommendations