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    A Forrester Consulting Thought Leadership Paper Commissioned By Bloomberg

    Financial Services Firms Accelerate Shift To

    Cloud-Based Archiving For Compliance

    April 2011

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    Forrester Consulting

    Financial Services Firms Accelerate Shift To Cloud-Based Archiving For Compliance

    Page 1

    Table Of Contents

    Executive Summary ................................................................................................................................................................................. 2

    Financial Services Firms Struggle With Compliance Requirements ............................................................................................. 3Half Of Financial Services Firms Plan To Adopt Hosted Compliance Solutions ....................................................................... 6Key Recommendations ........................................................................................................................................................................... 9Appendix A: Methodology................................................................................................................................................................... 10Appendix B: Supplemental Material .................................................................................................................................................. 10Appendix C: Demographics/Data ...................................................................................................................................................... 11Appendix D: Endnotes .......................................................................................................................................................................... 11

    2011, Forrester Research, Inc. All rights reserved. Unauthorized reproduction is strictly prohibited. Information is based on best available resources.

    Opinions reflect judgment at the time and are subject to change. Forrester , Technographics, Forrester Wave, RoleView, TechRadar, and Total

    Economic Impact are trademarks of Forrester Research, Inc. All other trademarks are the property of their respective companies. For additional

    information, go to www.forrester.com. [OrderID]

    About Forrester Consulting

    Forrester Consulting provides independent and objective research-based consulting to help leaders succeed in their organizations. Ranging in

    scope from a short strategy session to custom projects, Forresters Consulting services connect you directly with research analysts who apply

    expert insight to your specific business challenges. For more information, visitwww.forrester.com/consulting.

    http://www.forrester.com/consultinghttp://www.forrester.com/consultinghttp://www.forrester.com/consultinghttp://www.forrester.com/consulting
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    Market shift: Half offinancial services firms

    plan to expand or roll out a

    hosted compliance

    solution by the

    end of 2012.

    Executive Summary

    Organizations are increasingly adopting cloud-based solutions for message archiving due to perceptions of lower total

    cost of ownership (TCO), more rapid deployment capabilities, and other advantages

    vis--vis traditional software deployments. Small and midsize organizations in

    financial services have relied on software-as-a-service (SaaS)-based and hosted

    message archiving solutions for years. Yet, many of their larger counterparts have

    held off on leveraging this deployment model, citing security, operational, legal,

    and other concerns. The market, however, has reached a tipping point and will see

    significant adoption of cloud-based message archiving by financial services enterprises of all sizes over the next two

    years. In November 2010, Bloomberg commissioned Forrester Consulting to evaluate the current state of archiving and

    compliance in the financial services sector, capture enterprise expectations, and examine changes in anticipated

    application delivery models.

    Key FindingsIn conducting an online survey of 187 North American decision-makers with responsibility for compliance, messaging,

    and legal risk mitigation employed by financial services firms, Forrester found that:

    Financial services firms struggle with compliance. Fifty-five percent of respondents describe complying with

    data privacy laws as challenging. Also, decision-makers report significant difficulties in meeting litigation

    requirements, recording and archiving obligations, employee communications monitoring needs, and other

    regulatory requirements.

    Compliance challenges are multi-faceted. Edging out concerns about cost, 75% of the financial services

    decision-makers surveyed highlight concerns about reputational damage in conjunction with regulatory

    oversight and investigations. Respondents also cite major concerns with compliance-related application

    integration and lengthy response times.

    Financial services firms focus on a broad set of content and application types for compliance. In addition to

    email, organizations perceive file shares, physical records, line-of-business applications, mobile messaging, and a

    wide range of other content types and applications to be critical for regulatory purposes.

    SaaS-based and hosted archiving solution adoption is increasing at a rapid clip. About half of financial

    services firms plan to leverage hosted compliance solutions prior to 2013. While small and midsize customers

    account for the bulk of the customers for these services today, over the next 24 months, larger financial services

    organizations plan to ramp up adoption.

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    eDiscovery alert: Only 33% of

    financial services firms are

    very confident that they can

    demonstrate that their

    electronically stored

    information is accurate,

    accessible, and trustworthy.

    Financial Services Firms Struggle With Compliance Requirements

    In a late 2010 survey, Forrester found that 81% of respondents across all industries rated regulatory compliance as a

    critical or high priority for the next 12 months. 1 Certainly compliance in the financial services sector isnt trivial. Even

    though many organizations have faced stringent regulatory requirements for years, its clear that meeting archiving and

    compliance objectives proves painful for many organizations. For example, in a Q1 2010 Forrester survey, fewer than

    half of respondents reported satisfaction with their current message archiving solutions. 2

    Companies in the financial sector face an alphabet soup of regulations. While other

    regulations can apply, these obligations may include: US FINRA 3110, US SEC 17a-3 and 17a-4, UK FSA Code of

    Business Sourcebook, EU Data Privacy Directive, US state data privacy laws, US Federal Rules of Civil Procedure(FRCP), and various others related to tax, corporate, and labor requirements. Wading into this mix, our survey found

    that financial services firms face a broad set of frustrations in meeting regulatory and compliance challenges (see Figure

    1). While privacy concerns lead the list, financial services firms describe major challenges in meeting litigation

    requirements, recording and archiving obligations, employee communications monitoring requirements, and other

    regulatory demands.

    Our ongoing exchanges with

    enterprises via inquiry, advisory, and consulting engagements highlight that major

    challenges continue. Whats behind all of these difficulties? To address this

    question and to get further insight into compliance and archiving challenges and

    enterprise plans, Bloomberg commissioned Forrester to capture extensive survey

    data from financial services firms.

    To address this complex set of regulatory, compliance, and eDiscovery demands, many organizations have deployed a

    mix of disjointed applications. The resulting application fragmentation itself can be a major challenge. Archiving and

    retention management approaches, often built as separate, isolated, and incomplete initiatives, can't keep up with

    current digital asset growth and the mandates that enterprises must follow to manage content proliferation. Fifty

    percent of financial services decision-makers report that lack of integration across archiving, compliance, andeDiscovery applications inhibits their organizations cross-functional coordination for eDiscovery. Shifting from one

    application to another during the eDiscovery process adds a "transformation tax" in the form of added cost, increased

    time, and greater risk inconsistent technologies and policies add to eDiscovery pain.

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    Figure 1

    Financial Services Firms Face Challenges With An Array Of Compliance And Regulatory Obligations

    Base: 187 North American decision-makers responsible for compliance, messaging, and legal risk mitigation at financial firms

    Source: A commissioned study conducted by Forrester Consulting on behalf of Bloomberg, January 2011

    Compliance Challenges Come In Many FormsFinancial services firms report that the cost of addressing compliance requirements, difficulties in integrating with

    related systems, and slow response times stand out as major obstacles. Yet, potential reputational damage leads the list

    of concerns stemming from regulatory oversight, reporting requirements, and investigations (see Figure 2). Reputations

    matter a great deal in the financial services sector. Headlines matter consumers are fickle and often face low barriers

    in shifting to alternate financial services providers. In addition to cost concerns associated with investigations and

    eDiscovery, financial services firms take active steps to avoid allegations of improper activities or actual wrongdoing,

    and these concerns can play a big role in rolling out compliance and archiving programs.

    8%

    27%

    28%

    30%

    37%

    35%

    33%

    36%

    3%

    10%

    12%

    14%

    10%

    12%

    15%

    19%

    Other

    The SEC Investment Advisers Act of 1940

    Requirements related to outsourcing

    Other record retention laws

    Employee communications monitoring obligations

    Recording and archiving requirements ofemployee communications

    Litigation holds and other litigation requirements

    Data privacy laws

    Challenging Very chal lenging

    Which of the following represent top regulatory and compliance challenges

    as it relates to electronic communications for your organization?

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    Figure 2

    Compliance Challenges Stem From Multiple Concerns

    Base: 187 North American decision-makers responsible for compliance, messaging, and legal risk mitigation at financial firms

    Source: A commissioned study conducted by Forrester Consulting on behalf of Bloomberg, January 2011

    Organizations Focus On A Broad Set of Content And Application Types for RegulationeDiscovery and regulatory requirements arent just about email. The revised US Federal Rules of Civil Procedure

    (FRCP) highlight that a wide variety of electronically stored information can be relevant to eDiscovery. Seventy-eight

    percent of our respondents state that they have been involved in extracting detail from email systems for investigation,

    eDiscovery, or to respond to a regulatory request. The comparable figure is more than 35% for shared drives, physical

    records, and Microsoft SharePoint repositories. Looking ahead, its clear that financial services firms have major

    concerns about a broad array of content and application types (see Figure 3). For example, even with its relatively short

    history, more than one-third of respondents rated regulatory concerns around social media as important and over half

    give similar ratings to recorded voice data, instant messaging, and other types of unstructured and structured data.

    49%

    50%

    47%

    37%

    18%

    21%

    27%

    38%

    Lengthy response times

    Chal lenges integrating with related systems

    Total cost of meeting these requiremen ts

    Potential reputational damage

    Concerned Very concerned

    When thinking about the increasing amounts of regulatory oversight, reporting requirements,

    and investigations, how concerned are you by each of the following?

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    Figure 3

    Multiple Content And Application Types Are Important For Regulatory Purposes

    Base: 187 North American decision-makers responsible for compliance, messaging, and legal risk mitigation at financial firms

    Source: A commissioned study conducted by Forrester Consulting on behalf of Bloomberg, January 2011

    Half Of Financial Services Firms Plan To Adopt Hosted Compliance Solutions

    Enterprises anticipate significantly expanding SaaS-based and hosted archiving and compliance applications. Forty-

    nine percent of decision-makers in financial services expect to expand or roll out a hosted compliance archiving

    solution prior to 2013 (see Figure 4). Historically, small and midsize financial services firms accounted for the largest

    portion of customers for these solutions. Many of these companies grappled with a combination of very tight IT

    budgets and strict regulatory requirements, and for them, cloud-based solutions were a good fit. With deeper pockets

    and more extensive internal IT capabilities, however, many of their larger counterparts opted for traditional on-

    premises software deployments to address archiving and compliance objectives. This market reality is rapidly changing.

    For example, among financial services firms with 20,001 to 100,000 employees, 47% plan to roll out or expand a hosted

    compliance archiving solution by the end of 2012 (see Figure 5) These results clearly demonstrate that a broad mix of

    smaller firms and larger enterprises in financial services plan to adopt hosted compliance archiving solutions over the

    next two years.

    6%

    17%

    27%

    36%

    35%

    36%

    40%

    33%

    34%

    32%

    33%

    25%

    3%

    17%

    16%

    19%

    21%

    23%

    20%

    29%

    32%

    42%

    46%

    57%

    Other

    Social media (e.g., Facebook, LinkedIn, Twitter)

    Bloomberg Messaging

    Recorded voice data (e.g., recorded phone calls and voicemail)

    Corporate instant messaging

    Microsoft SharePoint

    Other document management/ECM

    Mobile messaging (e.g., BlackBerry messaging)

    Line-of-business applications (e.g., ERP, CRM)

    Physical records

    Shared drives/file shares

    Email

    Important Very important

    How important are the following sources of regulated content to your organization?

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    Figure 4

    Half Of Financial Services Firms Plan To Adopt Hosted Compliance Solutions Prior To 2013

    Base: 187 North American decision-makers responsible for compliance, messaging, and legal risk mitigation at financial firms

    Source: A commissioned study conducted by Forrester Consulting on behalf of Bloomberg, January 2011

    Figure 5

    Firms Of All Sizes Plan To Adopt Hosted Compliance Solutions

    Base: 187 North American decision-makers responsible for compliance, messaging, and legal risk mitigation at financial firms

    Source: A commissioned study conducted by Forrester Consulting on behalf of Bloomberg, January 2011

    Don't know22%

    Yes49%

    No29%

    Do you expect your organization to expand or roll out a hosted compliance archiving

    solution by the end of 2012?

    Size Yes No Dont know N

    501 to 1,000 employees 24% 31% 45% 29

    1,001 to 5,000 employees 60% 29% 11% 45

    5,001 to 10,000 employees 52% 26% 22% 27

    10,001 to 20,000 employees 79% 5% 16% 19

    20,001 to 100,000 employees 47% 37% 16% 38

    More than 100,000 employees 38% 35% 28% 29

    Do you expect your organization to expand or roll out ahosted compliance archiving solution by the end of 2012?

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    Total Cost of Ownership and Deployment Speed Drive Hosted Compliance AdoptionSo, whats behind this anticipated increased adoption for SaaS-based and hosted archiving and compliance solutions?

    Enterprises frequently express frustration with legacy on-premises message archiving software, and many are turning to

    service-based approaches. In comparison with traditional software applications, top drivers leading to adoption of

    hosted compliance archiving applications include perceptions of lower TCO, more rapid deployment capabilities, more

    attractive cost models, and other deployment and functional advantages (see Figure 6). As vendors continue to address

    security, operational, privacy, and legacy concerns associated with these deployment models, Forrester expects

    adoption of SaaS-based and hosted archiving and compliance to increase at a rapid clip.

    Figure 6

    Low Cost, Rapid Deployment, And Attractive Cost Models Drive Hosted Compliance Archiving Adoption

    Base: 92 North American decision-makers responsible for compliance, messaging, and legal risk mitigation at financial firms that plan to adopt a

    hosted compliance archiving solution

    Source: A commissioned study conducted by Forrester Consulting on behalf of Bloomberg, January 2011

    3%

    33%

    39%

    39%

    45%

    49%

    59%

    60%

    Don't know

    New regulatory requirements require an improved solution

    Superior compliance and archiving features andfunctionality compared with on-premises alternatives

    Global solution that can be easily deployed to all regions

    Improved search and retrieval capabil ities compared withon-premises alternatives

    More attractive cost model (impacting overall operational asopposed to capital budget) than on -premises alternatives

    Easier and faster to deploy and manage than on-premisesalternatives

    Lower overall total cost of ownership (TCO) than on-premises alternatives

    What factors are driving your organization to expand or roll out a hosted compliance archivingsolution by the end of 2012?

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    KEY RECOMMENDATIONS

    Regulatory requirements and eDiscovery pain are driving many organizations to expand or roll out archiving and

    compliance solutions. Over the next 24 months, about half of financial services firms plan to adopt hosted compliance

    archiving solutions to address these needs. This represents a major market shift, and as companies go down this path theywill need to navigate carefully. Forrester recommends that financial services firms:

    Take a close look at capturing advantages from cloud-based approaches but exercise caution. Hosted and

    SaaS-based compliance and archiving applications can deliver significant TCO, deployment speed, and other

    benefits, but companies should closely consider contractual and other supplier considerations. In addition to well-

    defined service-level agreements, enterprises should document provisions for security, potential data loss, and

    physical location of the data and ensure that these are sufficient for your organizations legal and corporate

    guidelines. Ultimately, youre on the hook for your content. Its important to recognize that cloud-based

    approaches dont absolve responsibility.

    Dont expect to boil the ocean, but plan for a broad range of content and application types. Litigation,

    investigations, and other regulatory actions often center on email. The survey findings, however, clearly show that a

    broad range of content and application types are critical from compliance and eDiscovery perspectives. Of course,

    its not feasible to apply archiving and compliance controls across all content types simultaneously. Instead,

    Forrester recommends focusing on content types and applications that provide the greatest legal risk mitigation

    and IT benefits, while weighting vendors cross-application functionality heavily during the selection process. Also,

    while eDiscovery demands loom largest in the US, litigation and compliance requirements affect organizations

    globally. Financial services firms must determine archiving needs across numerous country, regional, and local

    regulatory requirements.

    Make sure that you dont shift your digital landfill to the cloud. Many enterprises report difficulties in

    establishing retention policies and synchronizing legal hold functions. All too frequently, companies end up stalling

    on developing these policies and may simply not delete content due to litigation concerns. As a result, many

    organizations are steadily building up a digital landfill that creates IT and legal risk mitigation burdens. In

    transitioning to cloud-based approaches for archiving and compliance, financial services firms will need to ensure

    that they develop and implement retention and legal hold policies for content captured by their service providers.

    Emphasize stakeholder alignment. Without sufficient cross-functional collaboration across IT, legal, compliance,

    records management, business, and other roles in developing retention policies, organizations often stumble with

    change management, risking archiving and compliance program success. Make sure that your firm applies

    appropriate attention to aligning stakeholders in developing policies and gathering system requirements and look

    to support these efforts with governance structures.

    Take a close look at how your cloud solution will integrate with related applications. Fragmentation across

    archiving, compliance, and eDiscovery applications frustrates enterprises and leads to increased cost and risk

    during litigation and investigations. Financial services firms evaluating offerings should be leery of end-to-end

    vendor claims as these often reflect marketing hype as opposed to actual tight application integration. Companies

    should expect to work with different providers to support archiving and compliance and broader eDiscovery needs,

    but vendors with demonstrated integrated functionality (delivered natively or via proven partnerships) can

    facilitate archiving and compliance objectives.

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    Appendix A: Methodology

    In this study, Forrester conducted an online survey of 187 decision-makers in North America from financial services

    organizations to understand the regulatory and compliance challenges and concerns related to electronic

    communications. Survey participants included decision-makers responsible for compliance, messaging, and legal risk

    mitigation in firms with more than 500 employees. The survey began in December 2010 and was completed in January

    2011.

    Appendix B: Supplemental Material

    Related Forrester ResearchThe Forrester Wave: Message Archiving Software, Q1 2011, Forrester Research, Inc., March 4, 2011

    Q&A: eDiscovery Fundamentals For Content & Collaboration Professionals, Forrester Research, Inc., December 15,

    2010

    Q&A: Message Archiving Fundamentals For Content & Collaboration Pros, Forrester Research, Inc., September 7,

    2010

    Regulatory And eDiscovery Demands Drive A Growing Message Archiving Market, Forrester Research, Inc., March

    17, 2010

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    Appendix C: Demographics/Data

    Figure 7We Captured A Wide Distribution Of Organizations By Number Of Employees

    Base: 92 North American decision-makers responsible for compliance, messaging, and legal risk mitigation at financial firms

    Source: A commissioned study conducted by Forrester Consulting on behalf of Bloomberg, January 2011

    Appendix D: Endnotes

    1 Source: Forrsights Security Survey, Q3 2010.

    2 Only 45% of respondents reported satisfaction with their current message archiving solution. Source: Q1 2010 Global

    Message Archiving Online Survey, Forrester Research, Inc. Further findings from this survey are available. Source:

    Regulatory And eDiscovery Demands Drive A Growing Message Archiving Market, Forrester Research, Inc., March

    17, 2010.

    501-999employees

    16%

    1,000 to 5,000employees24%

    5,001 to 10,000employees

    14%

    10,001 to 20,000employees

    10%

    20,001 to 100,000

    employees20%

    More than 100,000employees

    16%

    "Using your best estimate, how many employees work for yourfirm/organization worldwide?"