Mother nature can deliver beautiful weather and at times devastating storms as Texas and soon Florida and more than likely the south east of the US will experience. The economic impact could be as high as $75 Billion. These events may bring to mind the importance of having a Disaster
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When it comes to Cyber Security the question isn’t “has your firm been hacked”, the question is “how often has it been attacked and to what extent?” Additionally, what are you doing about it? Are procedures and testing aligned with your systems and resources? Are your employees trained on how
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It’s all about the data. The SEC and FINRA want all the data they can obtain and then some. The SEC has successfully implemented NEAT and MIDAS, which collect trading data and can be used in a micro and macro environment – predicting trends, insider trading and other non-compliance actions.
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The Fall is quickly coming to an end and your compliance year-end tasks are now in front of you. Have you reviewed your checklist of required exams and tests? Have you reviewed and updated your compliance manuals with current rule changes and amendments? There were several significant changes again this
Read more →Year end AUM broken out by discretionary and non-discretionary assets should be confirmed – Do not include broker dealer assets if your firm is a hybrid – RIA & BD. The regulators do not look kindly on this especially if the additional assets move your firm from state to SEC
Read more →Red Flags 2014 BD and RIA hot topics. Regulators continue to amend and draft new regulations as they proceed to implement the JOBS Act, Dodd-Frank and consolidate the NASD/NYSE Rule books. The focus for this event is on the M&A Brokers No Action letter, Crowdfunding, Cyber security and Structuring a
Read more →Have you read through the FINRA Monthly & Quarterly Disciplinary Actions lately? My question is this: was the NASD just out of touch seven plus years ago, or were the exams just a routine ‘check the box’? Many of these compliance infractions should have been obvious to an examiner –
Read more →Beginning in Q3, the CEO and CCO(s) will receive the all-encompassing manifest of reports provided to you by your carrying firm(s). This package of reports will outline ALL the reports available to your firm as well as a list of the reports you have requested. The report listing already provided
Read more →Earlier this month, Commissioner Kara M. Stein reinforced very clearly the importance of compliance. From her stand point, being compliant is far more complex than just following the rules and checking boxes. Every person in financial services, at any level, has a responsibility to “do the right thing” and report when it is
Read more →Are the SEC and FINRA articulating their message of compliance requirements clearly? Has the volume become overwhelming? What do you think? The regulators are aggressively pursuing their agenda with broker-dealers and registered investment advisor firms like never before and ‘bad actors”’ will be punished severely. What do they mean by,
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