As I stated in an earlier post, I felt there were some additional things that needed to be addressed in this joint guidance. In the spirit of open communications and the NYSE’s receptiveness to feedback on the proposed guidance, MessageGate submitted comments.  They are posted on our website and will be posted on the NYSE’s site at some point.  Here are the highlights:

There are challenges related to supervising electronic communications including:

1. False positives resulting from binary keyword rules
2. Duplicate messages in the review queue
3. The burdensome review of internal messages which account for 70-80% of total volume
4. A significant cost of knowledgeable staff and infrastructure to perform the reviews

The second part details what technology can do to enable supervision beyond lexicon (keyword) or sampling based approaches including:

1. Segmenting electronic communication flows
2. Identifying "of interest" or suspect communications
3. Suppressing duplicate messages during review
4. Enforcing departmental/business unit controls and exceptions
5. Providing selective pre-send review

Here is a recent Q&A article with IT Business Edge where I lay this out from a business process perspective and one of our Instep Podcasts that covers the points above in more detail.

Download Instep_JointGuidance_final.mp3