Blog
Regulation S-P: Possible Compliance Weaknesses
SEC Risk Alerts are helpful tools that notify broker-dealers and investment advisors of trends identified during recent examinations. A Risk Alert released last year provides insight to assist Firms with staying in compliance, highlighting trends related to Regulation S-P. […]
AML and Branch Audits in the Time of COVID-19
At the beginning of the year, FINRA released important updates related to supervision requirements for broker-dealers. As broker-dealers and their employees started experiencing various work-from-home, virtual meeting, and operations challenges, FINRA provided valuable guidance for the transition in a FAQ related to the coronavirus pandemic. Below are a few items [...]
Best Execution Violation Takeaways
Disciplinary actions are often the best way to answer questions such as “how did this happen” or “what can we do differently”. Recently, a member firm named Robinhood Financial LLC was fined $1.25 million for best execution violations. Their shortcomings can provide valuable takeaways to assist other firms in building [...]
FINRA Continuing Membership Application (“CMA”)
When a broker-dealer implements a significant change in the strategies and activities of the business, FINRA requires firms to file a continuing membership application (“CMA”) to modify its membership agreement. Through this requirement, FINRA seeks to help protect investors by ensuring that firms reflect these changes in their policies, procedures, [...]
Cybersecurity in the Time of COVID-19
For many firms, a remote workforce is now a new reality. Even with many states’ shelter-in-place restrictions lifting, firms are continuing with their work-from-home strategies for the majority of their staff. This transition and the related challenges have forced firms to re-evaluate their current cybersecurity and remote policies and procedures. [...]
Disclosures and Attestations for Associated Persons
Associated person disclosures and attestations are not a “one size fits all” list of documents. The purpose of disclosures and attestations is to educate your employees on the expectations of the firm based on firm procedure and regulatory mandates. Another important purpose is to give representatives a chance to know [...]