On The Record – Mobile Voice Recording Update 2012

Published on Monday, 23 January 2012 10:10

Written by JP Reis

This blog should be a retrospective. Sadly it’s not. The exemption on mobile voice recording in FSA regulation PS10/17 was lifted in November but the surrounding issues are not resolved.

Some institutions have achieved compliance but that is not enough.  We discussed this topic  in May when Marc Henson explained that the key discovery phase question was “What is it I need to do and what are the consequences of not doing it right?” Marc revisits that question now.

Compliance, Reliability, Functionality

Financial institutions were given a tough choice on whether to concentrate on compliance, reliability or the impact on the functionality of their mobile devices. Understandably, compliance and reliability were prioritized. So when network managers at the majority of institutions asked themselves the question they actually had to accept that some degradation in performance would be the inevitable consequence of getting compliance and reliability right in the time available.  Why was this the case? Testing on the three criteria can be performed as follows:

• Reliability can be evaluated through stress tests under laboratory conditions
• Compliance can be measured by comparing empirical results against the stated regulations, once again under lab conditions.
• Impact on performance can similarly be assessed to provide estimates of user acceptance.

Unfortunately, laboratory conditions cannot uncover every real world issue in a limited timeframe:

• Reliability is typically expressed as Mean Time Between Failures.  Laboratory testing can’t always predict real world circumstantial failures and the compressed time period means that not enough failures are encountered for an accurate measurement to be made.
• Compliance is compromised if failures that remained undetected under lab conditions cause the solution to fail without the core application detecting or reacting to the failure.
• True impact on performance can only be assessed by users who require the application in order to carry out their function.  The delay between receipt of call and start of conversation which has been experienced may be acceptable to the casual user but not to the time-poor financial trader.

The short period between the regulation’s announcement and the day it went live meant that a very early decision had to be made on the adoption of a particular technology. Once selected, the only option was to continue on that path and try to mitigate issues as far as possible.

True TECHNOLOGY Implementation

The net result is that the task to engineer and adopt solutions that make mobile voice technology compliant in a reliable and usable fashion is not complete. It was generally recognised that a technology refresh would be required and this reengineering process actually began before the technology was even brought into service.  With the regulation now well established the pressure is increasing on all institutions to achieve not only compliance and reliability but also performance at a suitable level.

Contact JP Reis on-line or by calling 020 3008 8558 to learn how this is now possible.