Blog
AML and Suitability Challenges During COVID-19
FINRA Rule 3310 provides broker-dealer guidance on how to design, test, and enforce a firm’s Anti-Money Laundering Program (“AML”). One main element of AML is to “establish and implement policies and procedures that can be reasonably expected to detect and cause the reporting of transactions required under 31 U.S.C. 5318(g) [...]
Compliance and COVID-19: Opportunities for Growth
The spread of the COVID-19 pandemic has presented challenges for many financial service firms. Compliance programs are no exception. Firms are generally responsible for building, testing, and enforcing their compliance programs. […]
Teleworking Considerations During COVID-19 Pandemic
Many financial service institutions have been hesitant to create teleworking processes and systems that would give them more flexibility to service clients and build the business. However, within the regulatory framework, landmines appear at every turn. […]
BCP and COVID-19: Considerations for Firms
Many financial service firms have written supervisory procedures in place for business continuity planning (BCP). Tucked somewhere on a server or in a binder, many plans have been collecting dust. More than likely, these plans are only taken out during regulatory exams, branch audits, or internal testing. […]
U4 Disclosure Updates: Cautionary Tales
Failure to timely update information on individual Form U4 disclosure may lead to potential fines and suspensions for a Registered Person. This is especially the case if the act was done intentionally. […]
FINRA Proposal to Enhance Continuing Education
The Securities Industry/Regulatory Council on Continuing Education (CE Council) recently presented a proposal to FINRA regarding Continuing Education (CE) requirements. The request for comments expires on April 20, 2020. […]