Crédit Suisse takes Compliance Online: How E-Learning has helped with Compliance

Library Hi Tech News

ISSN: 0741-9058

Article publication date: 1 August 2003

165

Citation

O'Sullivan, T. (2003), "Crédit Suisse takes Compliance Online: How E-Learning has helped with Compliance", Library Hi Tech News, Vol. 20 No. 8. https://doi.org/10.1108/lhtn.2003.23920haf.003

Publisher

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Emerald Group Publishing Limited

Copyright © 2003, MCB UP Limited


Crédit Suisse takes Compliance Online: How E-Learning has helped with Compliance

Crédit Suisse takes Compliance Online: How E-Learning has helped with Compliance

Tara O'Sullivan

The financial services industry in Europe faces many challenges as it attempts to maximise cost savings, leverage acquisitions and cope with the stresses of changing delivery channels and the need to bring new products and services to market faster. Additionally, the industry must deal with dramatic changes to compliance legislation in Europe and internationally, which bring new levels of risk, both corporate and personal, to senior executives.

Companies in highly regulated industries must respond by finding innovative solutions to cut costs and improve efficiency, while at the same time not letting up on its need to retain and acquire customers, bring new products to market and maintain regulatory compliance.

Crédit Suisse Financial Services has chosen the TopClass e-Learning Suite as their corporate e-Learning solution. This enterprise-wide contract follows a successful three-year deployment at Crédit Suisse Private Banking, where TopClass was used to deliver online learning to 8,500 employees. The initial focus of the expanded deployment is legal and compliance training to all 50,000 staff and sales training to the Group's 4,000-strong sales team.

The compliance challenge

In the last few years the sheer number and scope of proposed and implemented compliance legislation changes have been overwhelming. Within the European Union, initiatives arising out of the EU Financial Services Action Plan are now moving ahead at a pace unheard of, with some 45 proposals under evaluation that will recast the financial services regulatory environment across the EU to a significant degree in the short to medium term. These changes are designed to provide a level of harmonisation and, ultimately, simplification to the varying legislation that has existed in member states; it is undoubtedly the case that, while we endure the transition period, the level of work involved in understanding and complying with the old and the new has increased significantly.

Within the UK, the relatively new Financial Services Authority (FSA) provides a centralised organisation for the management of compliance. While the FSA does not regularly audit banks in the way that an auditor might, banks are required to fulfil a number of obligations such as submitting a set of annual accounts to the FSA. The FSA has the power to investigate and inspect a bank, when they suspect something is awry, and they can impose substantial fines.

The German financial services industry is considered to be one of the most tightly regulated in Europe. In May 2002 the new German Financial Supervisory Authority (Bafin) became the single agency for financial services supervision in Germany. It brings together existing regulatory agencies under one umbrella with separate directorates for banking supervision, insurance supervision and securities supervision. In addition, a number of cross-sectoral departments were established to look at industry-wide issues such as consumer and investor protection, anti-money laundering and the fight against terrorism.

Globally, the Basel Committee on Banking Supervision is working on amending the existing Capital Accord, which will result in a greater emphasis being placed on financial institutions, own assessment of the risks to which they are exposed in the calculation of regulatory capital charges. These changes will impact virtually every financial services provider in the world whose country is a signatory to the Basel Committee charter.

The changing nature of compliance

Not only has the compliance environment begun to change in terms of the source of the legislation (new statutory bodies) and their scope (due to harmonisation), but also the burden of compliance is being moved more to the financial services providers themselves. In many cases this includes direct and personal accountability being placed on employees and management of the providers, with stiff personal penalties including fines and potential incarceration.

Aspects of this changing approach to compliance include:

  • A move from a more prudent regime with strict guidelines for financial reserves and other areas to a more risk-based assessment where the provider has more leeway to decide what is appropriate based on the environment.

  • A change from sector-based regulations, which are differentiated based on geography and industry (such as insurance, banking and so forth), to a more harmonised approach, often under one industry-wide regulator, e.g. FSA, Bafin.

  • A significant shift from vague organisational level responsibility to clearer personal responsibility.

  • Focus less on formal returns to the regulatory body such as the FSA to an environment with risk management procedures and control policies in place that allow for and are subject to unscheduled audits by FSA personnel.

  • Less reliance on the professionalism of provider employee and management to identify and provide appropriate information on suspicious transactions, to a regime that imposes criminal penalties for failure to notify authorities of any suspicious activity by customers or fellow employees.

In many ways, this new approach to compliance is designed to provide greater flexibility in the decision-making process for an institution to determine what it needs to do to remain in compliance. At the same time, it places much greater responsibility on both the institution and personnel to evaluate risks and make appropriate decisions.

How e-Learning can help

e-Learning is renowned for reducing costs and increasing speed of training as well as being more appealing to learners due to the self-paced nature of many of the courses. e-Learning also provides a centralised repository for managing the enterprise-wide training solution and offers detailed tracking and assessment capabilities.

A Learning Content Management System offers e-Learning content management and assembly, personalised content delivery, learner collaboration, learner tracking and assessment, Web-based training administration and database administration. Learning Content Management Systems (LCMS) work in conjunction with the traditional Learning Management Systems (LMS) to manage the course content.

Enterprises should think of compliance content in terms of Learning Objects or "nuggets" that are developed over time and then assembled. Such an approach will also optimise reuse.

A comprehensive e-Learning solution can help in a number of key areas:

  • Manage the regulatory environment by providing a defensible audit-proof centralised management environment.

  • Leverage Customer Relationship Management initiatives to generate new revenue and retain customers.

  • Reduce risk by driving understanding of risk management processes and technologies.

  • Bring new products to market faster with product introduction training.

  • Reduce the development cost and time of training materials by developing smaller chunks of learning.

  • Speed the time to performance of employees by delivering personalised just-in-time learning.

  • Lower delivery costs by reducing reliance on third-party classrooms and increase access to learning any time, any place.

The Crédit Suisse experience

Crédit Suisse Group is a leading global financial services company headquartered in Zurich. Crédit Suisse Financial Services provides private clients and small and medium-sized companies with private banking and financial advisory services, banking products, and pension and insurance solutions from Winterthur. Crédit Suisse Group's registered shares (CSGN) are listed in Switzerland and Frankfurt, and in the form of US Depositary Shares (CSR) in New York. Founded in 1856, the company has almost 150 years of experience and operates in over 50 countries with over 50,000 staff.

As a global institution, Crédit Suisse must observe the legal and compliance regulations of many different countries and this poses a challenge in terms of training its world-wide staff and ensuring they are compliant in the countries in which they operate. The Swiss Federal Banking Commission (SFBC) has been increasing the amount of regulatory control and monitoring of the Swiss financial environment with anti-money laundering and client data protection as key areas of focus. In foreign locations, Crédit Suisse maintains compliance with Swiss regulations in addition to the policies of any regional regulatory authorities. Every significant Crédit Suisse location has a legal unit including a legal and compliance officer, and the reporting requirements for a legal and compliance officer may differ in each region based on the local regulatory authority.

"TopClass is a comprehensive e-Learning Suite and WBT Systems' services are top-notch," said Anthony Cerquone, Head of Talent Development and Leadership Technology, Crédit Suisse Financial Services. "We chose WBT Systems because of their understanding of our business. The commercial, competitive and regulatory environment in which we play is very complex and WBT Systems understand this. They are helping us to respond to these challenges with innovative solutions to cut costs and improve efficiency."

"Crédit Suisse is committed to ensuring compliance with the regulatory obligations in every location in which it operates." continued Mr Cerquone. "Like all large financial institutions, this imposes an enormous training obligation, which would be almost impossible to meet with traditional classroom training. For example, we and our colleagues in Legal & Compliance have developed "Case of the Month", a scenario-based approach to testing staff on work situations that require an understanding of compliance. This course is mandatory for several thousand employees every month, as well as being available to all others. With the help of WBT Systems and TopClass, we look forward to meeting and exceeding these obligations."

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