Intelligent Voice® for Dodd-Frank

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to find out how Intelligent Voice can help solve your Dodd-Frank requirements

If you are reading this, then you are probably having sleepless nights. Dodd-Frank introduces record-keeping and disclosure requirements that go beyond the current state of technology.

Dodd-Frank Compliance

If you are involved in OTC Derivative Swap trading, then Dodd-Frank compliance dictates you need to keep all communications relating to the trade. This means everything, including telephone calls. Not only do you need to keep it, it has to be in a non-erasable form, and it has to be retrievable by transaction and counter-party.

The capture issue is probably the easiest. There are plenty of products that will allow you to capture and store text based communications, eg e-mail and IM. Landline telephone capture is also pretty straightforward, be it from an IP-based network or a more sophisticated turret system. Intelligent Voice has an optional capture module to allow full-stereo, high-quality phone capture.

Cell phones are more complex, as you do not have control over the core of the architecture. Bear in mind that however you choose to manage the collection of cell phone data, it needs to comply with the Dodd-Frank storage requirements.

Meeting Dodd-Frank Reporting Requirements

Under s1.31 of the Commodity Exchange Act, all electronic records need to be kept "exclusively in a non-rewritable, non-erasable format". That doesn't necessarily mean it has to be on a completely non-erasable medium, but WORM storage is an obvious option, especially if you segregate shorter term data, such as voice data, from longer term data such as e-mail, which has a longer retention requirement.

The biggest problem, though, is the retrieval requirement. Until the swap is concluded, it does not get its Unique Swap Identifier (USI).

So to meet Dodd-Frank reporting requirements, you have the mother of all search tasks. You have to identify who might have been a communicating party. Then you have to sift out from all of those communications the ones that relate to the trade. And given that over any given period the same people might have multiple discussions about multiple transactions, that is not so easy.

IV helps because it allows you to identify phone calls by what was said in them, not just by who was a party to the communications.

But there is one more step that you have to take. Over 40% of all phone calls into financial institutions have no caller ID information. This means you cannot pull together communications using the structured telephone number metadata. IV can, optionally, allow you to highlight unknown callers, and group them by voiceprint. It is then a simple matter of matching the voiceprint to an individual to allow counter-parties to be identified.

IV has built-in timeline tools to enable you to gather and present data, or it can work with third party tools such as Clearwell to provide advanced collection and analysis.

Dodd-Frank White PaperDownload our White Paper "Beyond Dodd Frank"

Key points

  • All communications need to be stored. Telephone calls now have a 1 year retention period.
  • Data must be stored in a non-erasable, non-rewritable form
  • Records must be "readily accessible"
  • Automatic identification of transactions is technically challenging, if not impossible. CAVEAT EMPTOR.
  • Voiceprint technology is the answer to blocked Caller ID

Are your voice recordings Dodd-Frank ready?

It's no use reaching the disclosure stage, and realising that your voice recordings are unintelligible. Here are a couple questions to ask of your current voice recording infrastructure:

  • Are your recordings retrievable with a separate voice on each channel (eg stereo for a normal call)
  • Are they stored at the original quality, or are they compressed?
  • Can you find recordings by keyword?

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