CoMetrix Compliance Operations
Overview
In order to meet ASIC's regulatory monitoring and supervisory compliance requirements, dealer groups must be able to demonstrate that regular compliance audits are carried out with each representative. Audits of client files include standard issues representatives must address with their clients - for example, provision of Financial Services Guide and Statement of Advice, disclosure of commissions, etc. The results of the audits are themselves subject to audit by ASIC.
CoMetrix supports compliance auditing requirements by providing:
- an operational system that supports compliance officers throughout the data collection and reporting process,
- procedures to ensure that action items are followed up, and
- management reporting that enables board members to assess their confidence in the dealer group's overall compliance performance.
Workflow and Questionnaires
CoMetrix allows auditors to capture responses to audit questions using a forms-based survey engine. Multiple questionnaires that are to be used for differing purposes can be assembled from hundreds of questions. Such questionnaires may include practice, documentation, due diligence, client investment, client risk, and adviser self-assessment.
The system uses a flexible workflow that guides auditors and advisers and paraplanners through an automated process. Workflow activities may be shared among multiple individuals who can collaborate on shared questionnaires. This means that advisers can allocate questions to their "practice champion", and auditors can continue work on behalf of their colleagues who may become unavailable due to annual leave, etc.
A report to the adviser is generated by the system. Quality control is maintained through generation of "exception text" and action plan items, based upon a common database for the dealer group. A facility is provided for manual editing of the report, followed by completion of the process by conversion to PDF with an email to the adviser.
Audit performance may be assessed either by assessing breaches in various question categories, or by assessing an overall score where a scoring system is used.
Prior to report generation, the auditor may review any breaches that have been detected, and is given the opportunity to override automatic failure of the audit. Following conversion to PDF, the adviser has an opportunity to register a reply to the audit, which may result in regeneration of the report.
Follow-up
A list of action plan items is presented to the adviser, who checks off the list as it is completed. A dealer group representative (practice development manager or auditor) verifies that each item has been done.
Management Reporting
The system provides reporting to help management assess the dealer group's compliance performance. Information is provided in both tabular and graphical form, for ease of visualisation. Examples are listed below:
- Individual adviser compliance scores (where a scoring system is used)
- Graphical summaries of distribution of authorised representative compliance scores (where a scoring system is used)
- Offices compliance scores (where a scoring system is used)
- Distribution of offices results (where a scoring system is used)
- Distribution of authorised representative results
- Breakdown analysis by question for the reporting period, by question type
- Top ten systemic issues with drill-down to individual advisers per issue
- Adviser results for the year to date
- Summary of new/cancelled authorised representatives and offices closed
- Summary of authorised representatives by active/non-active status