This might seem intuitive, but is not always the case. Depending upon your investment management division’s interaction with the compliance team, responsibilities may only be published in a compliance manual and sitting on a shelf. In many cases not only was it not read, but may not even be locatable.
Read more →Compliance is considered a cost center by most; the more enlightened will view it as a form of insurance, protecting their financial standing and maybe even more importantly their personal and business reputation. Knowing your risk exposure will help you understand your potential liability as an enterprise. Business risks come
Read more →If your firm, staff or Advisors have been affected by any of the storms this year, this may be an opportune time to document the events your firm is experiencing and satisfy 4370(b). There has rarely been a better time to test and document your Business Continuity Plan (BCP) procedures
Read more →FINRA is playing it close to the vest, giving you until February 21 for input on its concept to develop a new oversight system – Comprehensive Automated Risk Data System (CARDS). Regulatory Notice 13-42 outlines the purpose of this new technology. Some may look at this initiative as completely intrusive
Read more →A very busy time of year indeed; nevertheless, we need it all and then some. Just as every day is a new day, every year brings new challenges. Most companies close the books and tasks on a calendar year-end basis. If your firm is one of them, it’s time to
Read more →November 20, 2013 is the day the SEC Red Flags rule becomes effective. Does your firm fall under the definition of firms required to adopt these rules? Is your Identity Theft Red Flags rule procedures documented? Do your procedures meet all the requirements? Do your procedures include, at a minimum
Read more →FINRA will file with the SEC a proposed rule change regarding recruiting bonuses paid to Registered Representatives for moving from one broker-dealer to another. There are two mechanisms to the proposal; disclosure and reporting to FINRA. The disclosure to customers is designed to assist them in making a decision whether
Read more →We are all aware that the purpose of FINRA’s Broker Check was to give both the public and financial services firms the ability to view both broker-dealers’ and registered representatives’ status with FINRA. The report briefly discussed the profile of the firm or individual and also identified any disciplinary events.
Read more →FINRA recently announced a new exam program and data collection technology. The new program is now being based off your firm’s risk as defined by FINRA. FINRA has many data collection points – Form BD, Form BR, U-4/U-5 filings, FOCUS reports, SSOI filings, OATS, TRACE… the list goes on. The
Read more →Trade Desk Supervisors and Chief Compliance Officers are required to establish, maintain, implement and monitor the firm’s supervisory procedures for trading, whether proprietary or in customer accounts. In some instances, the trading function of the firm is where revenue is generated and profits are made. Your procedures should address the
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