Watchlists are not just the stuff of regulation; they can also be how the firm institutes its own set of restrictions. The question is: can you incorporate your own internal lists into your other watchlist screening efforts, and what flexibility do you have in that regard?
Questions to consider:
- Can you define multiple functional lists? Can they be separated out physically, as separate lists? If not, is the process for differentiating between entries of different types (e.g. through a type code or other identifier) easy to leverage in your screening applications?
- What control do you have over the data elements? Can you create custom fields? Can you control which fields are used for creating matching phrases?
- What control do you have over matching phrase creation? Can you generate a default set of phrases for a given entry? Can you do that in bulk (i.e. enter all the data, then press a button to fill in all the blanks)? Can you add, change and/or delete matching phrases, whether they were manually created or automatically generated?
- Can you import an existing list you have in some other format (like, from Excel)? What are the options available with that? Can you specify default values if a required element is not in your current list file? If you import multiple times, does it append to the current list, replace the entire current list, or does it replace newer versions of the same record, and create new records when it can’t find an existing one?
- Can you wipe out all existing records in bulk if you needed to (e.g. like a 314(a) list)?
- If the vendor supplies a private list maintenance application (Accuity, my employer, has a nice one), as opposed to importing your data directly into the screening application, do the export capabilities make integration into other applications reasonably easy? In other words, if you have two screening solutions that both need your private lists, can one list maintenance application provide exported files that could be imported into both screening applications – or do you have to maintain the list in multiple places?
Categories: Operational Procedures