After you have built a lexicon of keywords, you can use it in searches to narrow the volume of results, which you then randomly sample by percentage or number of communications. Random sampling of the data in your organization is a FINRA requirement. The compliance officer must send, on a daily basis, a percentage of sample data for compliance verification. This same process may repeat on a monthly basis to include all the data from the previous month.
Sampling is applied when you open an audit for the first time according to the sampling settings (size and interval). Sampling is applied to documents that:
- Meet the search criteria
- Have not been tagged "ForReview"
- Were created since the previous sampling
- After the expiration of the sampling interval
For example, if the sampling interval is 2 days, a new sample is created every other day as opposed to every day to avoid resampling the same day twice. Sampled documents are tagged "ForReview" and displayed in the Results tab.
Also, if needed, you can force a random sampling event mid-interval whereby the sampling is applied to all documents created since the previous event; essentially the sampling interval expiration is disregarded.
If NetGovern Search is set to preview items in the side pane, clicking an item will indicate it as reviewed. It will then be removed from the Results tabs.
Random Sampling Strategy
Here is a four-part random sampling strategy you can apply to your organization, depending on its size.
- Randomly apply keywords to 15% of all emails in your organization.
- Repeat on another 15% chunk of emails, targeting key staff, such as portfolio managers, traders, sales people, and executives.
- Randomly flag another 30% of emails.
- Search the remaining 40% of emails for phrases, such as “great performance” or “guaranteed performance.”