Blog
The Importance of Form U4 Disclosure Updates
Failure to timely update information on an individual form U4 may lead to potential fines and suspensions for a registered person, especially if the act is willful. Examinations and sweeps performed by FINRA generally reveal exceptions. […]
Mid-Year Compliance Budget Planning
Reviewing your current mid-year compliance budget plan and adjusting for the rest of the year is important. With COVID-19 taking up a substantial portion of the first half of the year, your vision and budget for 2020 may have drastically changed. […]
FinCEN 314(b) Program FAQs
Our previous blog post focused on FinCEN’s 314(a) program and what this requirement means for firms. We now switch our focus to the FinCEN 314(b) program and its implications to firms. […]
FinCEN 314(a) Program FAQs
The Financial Crimes Enforcement Network (FinCEN) is a service driven by law enforcement agencies to coordinate with covered financial institutions to help locate financial assets and transactions by subjects of criminal investigations, such as tax fraud or money laundering investigations. FinCEN is also a bureau of the U.S. Treasury Department. [...]
Code of Ethics Concerns During COVID-19 and Beyond
COVID-19 has bought a “new normal”. From stay-at-home orders and teleworking requirements to market volatility, consumer worry, and delayed public disclosure, the face of the industry will be forever changed. In light of this, Registered Investment Advisor compliance departments should consider reviewing the landscape of the Code of Ethics requirements. [...]
Third-Party Outsourcing Best Practices
Complete reliance on third-party outsourcing may negatively impact your compliance program. Other firms’ mistakes can serve as valuable cautionary tales to guide your decision-making process when establishing and maintaining relationships with third-party vendors. […]