FINRA Rule 3110(a)(7) requires all registered representatives and registered principals to participate, at least once each year, in an interview or meeting at which compliance matters relevant to their particular activities are discussed. Annual Compliance Meetings (ACM) give registered persons the opportunity to regularly discuss compliance issues and assists the firm in ensuring that registered persons remain current on applicable regulatory developments or changes in firm policies.
Hosting an Annual Compliance Meeting
These meetings can be held individually or with a group and typically take place at a central location or at the representative’s or principal’s place of business. These meetings often require associated persons to fill in, date, and sign a sign in sheet, annual compliance questionnaire (ACQ), or attestation developed by the firm.
They may, however, be conducted by video conference, telephone, interactive classroom setting, or other electronic means so long as certain safeguards are in place to assure full participation. Examples of safeguards would be assigning a unique ID and a password to each rep to evidence that they attended the online ACM or including interactive features such as quizzes during the meeting to ensure participation.
What to Include in an ACM
FINRA’s stance is that it would not be possible to provide an exhaustive list of the topics that should be addressed at a compliance meeting. The purpose of the compliance meeting is to provide firms with the opportunity to review compliance matters relevant to their registered persons. Those relevant matters, in turn, will depend on the business of each firm and the particulars of their compliance policies and procedures.
However, FINRA does provide resources from which a firm may draw from to devise suitable topics to discuss with its registered persons, particularly as they relate to regulatory developments. Compliance resources may include FINRA publications such as the annual Risk Monitoring and Examination Priorities Letter, Report on Examination Findings and Investor Alerts, and more. For example, if the firm conducts the meeting online,
ACM and Continuing Education
FINRA recently adopted changes to its continuing education rule to expressly allow firms to consider training relating to the anti-money laundering compliance program under Rule 3310(e) and the annual compliance meeting under Rule 3110(a)(7) toward satisfying an individual’s annual Firm Element requirement.
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