Compliance Quick Wins: MiFID II and Corporate Access Hygiene

Keep investor access compliant without slowing your team down. MiFID II, Reg FD, and internal disclosure policies create real risk for IR and corporate access teams, but most compliance failures aren’t intentional violations—they’re process gaps that show up under pressure. These quick wins reduce risk while keeping booking friction low and audit trails clean.

What You’ll Achieve

  • A lightweight compliance checklist built into your daily workflows
  • Cleaner audit trails across invitations, meetings, and follow-ups
  • Fewer last-minute disclosure and blackout issues that delay or cancel meetings

Map the Risk Points in Your Workflow

Compliance failures happen at predictable moments in the corporate access lifecycle. Identify those moments, build controls around them, and you’ll catch problems before they escalate.

Targeting and invite language. Who you invite and what you say in the invitation can create selective disclosure risk. If you’re inviting only long-only funds to a small group session where the CFO will discuss margin guidance, you may be giving those investors material information that short sellers and other market participants don’t have. Ask Legal to review your standard invite templates and flag language that could imply access to non-public information.

Materials control and versioning. Presenting outdated financials, using a deck that contradicts your latest 8-K filing, or sharing slides that haven’t been cleared by Legal can trigger SEC scrutiny. Version chaos—where different team members are working from different drafts—is the most common cause. If your CFO presents one set of numbers in a morning meeting and a different set in the afternoon, you have a disclosure problem.

Blackouts, quiet periods, and selective disclosure. During earnings blackout windows, most companies restrict or prohibit investor meetings to avoid inadvertent disclosure of material information. If your access team doesn’t have visibility into the corporate calendar and disclosure schedule, they’ll book meetings that Legal has to cancel at the last minute. Worse, they’ll schedule meetings where executives accidentally leak guidance updates or M&A plans because nobody briefed them on what’s off-limits.

Lightweight Controls That Actually Stick

Compliance controls fail when they’re too manual, too complex, or disconnected from how people actually work. Build controls that run in the background and require minimal effort to follow.

Standard invite blocks with compliant language. Write three to five email templates for common scenarios (conference 1:1s, NDRs, analyst days, maintenance calls) and have Legal approve them once. Store these templates in your corporate access platform or email system so the team can’t accidentally send non-compliant language. Include standard disclaimers about Reg FD, note that discussions will be limited to publicly available information, and link to your latest earnings release or investor presentation.

One source of truth for decks with role-based permissions. Store all investor-facing presentations in a single shared folder with version control and restricted access. Only designated approvers (IR lead, Legal, Finance) can edit or upload new versions. Everyone else pulls read-only copies from that folder. Lock the final version 48 hours before the first meeting, and require sign-off from Legal and Finance for any post-lock changes. Log every edit so you can reconstruct what was presented to whom if a question arises later.

Pre-flight checks before send and before go-time. Before sending meeting invitations, run a checklist: Is this during a blackout window? Has Legal approved the invite language? Is the target list appropriate (no selective access issues)? Before the meeting starts, run a second checklist: Is the exec using the approved deck? Have they been briefed on disclosure limits? Is someone from IR or Legal on the call to monitor? Automate these checklists in your workflow tool so they can’t be skipped.

Build Audit Trails by Default

Compliance audits happen fast, and you can’t reconstruct what happened six months ago if you weren’t capturing data along the way. Design your workflows to log key events automatically.

Calendar attachments and confirmations stored centrally. Every meeting invitation, confirmation, and calendar update should be saved in a central system—not scattered across individual email inboxes. Use a corporate access platform that logs every invite sent, every response received, and every schedule change. If an investor later claims they weren’t told about a blackout or didn’t receive meeting materials, you can pull the audit log and show exactly what was sent and when.

Attendance captured automatically without portal logins. Don’t rely on investors to log in to a portal to confirm attendance. Use calendar acceptances and video platform join logs to track who attended, when they joined, and how long they stayed. Export this data weekly and store it in a compliance-friendly format (e.g., append-only logs that can’t be edited after the fact).

Post-event notes with owner and timestamp. After every meeting, the IR team member or banker who staffed the call should log a brief summary: topics discussed, questions asked, materials shared, and any follow-up commitments. Include the author’s name and timestamp. Store these notes in the same system as your invite and attendance logs so auditors can see a complete timeline from invitation to follow-up.

Data Minimization and Retention

MiFID II requires transparency around corporate access, but that doesn’t mean you should store every piece of investor data forever. Collect only what you need, and delete it when you no longer need it.

Minimize PII collection. Do you really need investors’ phone numbers, personal email addresses, and home addresses? Or can you operate with firm name, work email, and role? The less personal data you collect, the lower your privacy risk and the simpler your compliance obligations under GDPR, CCPA, and similar regimes. Review your intake forms and CRM fields, and delete any fields that aren’t essential.

Set retention policies and enforce them. Define how long you need to keep meeting records, attendance logs, and presentation decks for regulatory and business purposes. Many firms keep these for three to seven years. After that period, delete them automatically. If you’re storing video recordings of meetings, apply shorter retention (e.g., 90 days) unless there’s a specific reason to keep them longer. Longer retention means more data to secure, more data to review in audits, and more exposure in litigation.

Role-based access and SSO/SAML. Not everyone on the team needs access to every meeting record. Implement role-based permissions so junior coordinators can schedule meetings but can’t see sensitive notes or materials. Require single sign-on (SSO) with multi-factor authentication (MFA) so you can enforce strong passwords and quickly revoke access when someone leaves the team. Avoid shared accounts or generic logins—every action should be traceable to a specific person.

Train Your Team and Run Drills

Compliance isn’t a one-time setup—it’s a muscle you have to exercise. Train your team regularly, and test your processes under pressure.

Quarterly 20-minute refreshers. Don’t wait for annual compliance training. Run short, focused refreshers every quarter that cover recent incidents (anonymized case studies from your firm or the industry), updates to blackout policies, and new tools or templates. Keep these sessions practical—walk through real scenarios like “An investor asks the CFO about next quarter’s bookings during a 1:1” or “Legal extends the blackout window the day before a scheduled NDR.”

Incident runbook and contact tree. When something goes wrong—an exec accidentally discloses material information, a deck with incorrect numbers gets shared, a meeting gets scheduled during a blackout—what happens? Who gets notified? Who decides whether to issue a corrective disclosure? Write a one-page runbook that lays out the steps, owners, and timelines. Include a contact tree with cell phone numbers for Legal, Compliance, IR lead, and the executive team. Test this runbook once a year with a tabletop drill so everyone knows their role.

Need a Compliance Checklist?

Request a demo to see how WeConvene builds compliance controls—audit trails, blackout enforcement, and pre-flight checks—directly into your corporate access workflows.

About WeConvene

Established in 2012, WeConvene is the cloud-based meetings and events management and marketing platform that helps the capital markets community book better®. WeConvene makes the creation, distribution, marketing and execution of official meetings and events between analysts, corporates, investors, IR firms, expert networks and investment banks fast and easy, generating better outcomes including greater team efficiency, increased meeting attendance and enhanced client satisfaction. For more information please visit WeConvene.com. For a demo or sales introduction please click here to request now.

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