Blog
Supervisory Control: The Basics of Rule 3120
Most broker-dealers are aware of their annual requirement to test and document their firm’s compliance program. But, the question remains if firms are meeting the full requirements of the rule. Below are the basics of the former NASD Rule 3012, now FINRA Rule 3120, for establishing and maintaining a system [...]
Supervision of Supervisory Personnel
FINRA Rule 3110 provides the requirements for building and maintaining a supervisory structure that is in compliance with rules and regulations. Among other requirements, this rule addresses the documentation and supervision of supervisory personnel in 3110(b)(6). What is FINRA Rule 3110(b)(6)? Rule 3110(b)(6) requires firms to document supervisory functions and [...]
Challenges with Outside Business Activity Disclosures
An outside business activity (“OBA”) is defined as a registered person having any business activity outside the scope of the relationship with their member firm. As defined in FINRA Rule 3270, this may include acting as an employee, independent contractor, sole proprietor, officer, director, or partner for any other entities [...]
FINRA Examination: How to Prepare
You get that call, and your heart drops. You knew that a regulatory exam was on the horizon, but you have put off thinking about it. Now, you are face-to-face with an upcoming FINRA examination, and the panic has set in. […]
Why Small Firms Need Compliance Program Assessments
With the rise in new regulations, small firms generally experience some of the greatest challenges evolving their business to meet these new demands. Critical focus areas constantly expand related to cybersecurity, senior investor protection, supervisory controls, succession planning, and human capital. With this in mind, small firms need to ensure [...]
Best Practices for Outsourced Vendors
Does your firm know who its key outsourced vendors are? Does your firm perform ongoing due diligence that includes an assessment of risks? The answers to both questions may involve a huge undertaking for small firms that have limited resources. […]