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Customer Identification Program (CIP): Common Questions – Part II
[Continued from Customer Identification Program (CIP): Common Questions – Part I] What Is A “Reasonable Time” To Verify Customers’ Identities? A customer’s identity must be verified within a “reasonable time” before or after the customer’s account is opened. The rule does not specify what counts as a “reasonable time,” and [...]
Customer Identification Program (CIP): Common Questions – Part I
In our previous post on customer identification programs, “Customer Identification Program (CIP): Definitions and Requirements,” we defined “account” and “customer” and went over the minimum requirements for CIP procedures and verification, including touching on non-documentary means of identity verification. This post will get a little more specific, addressing common questions [...]
NASAA Proposes Information Security Rule for RIAs
The North American Securities Administrators Association, Inc. (“NASAA”) is requesting public comment regarding a proposed model rule for information security and privacy for registered investment advisers (RIAs) under the Uniform Securities Acts Of 1956 And 2002. NASSA has been actively working on addressing various investment adviser-related cybersecurity concerns and desires [...]
Customer Identification Program (CIP): Definitions and Requirements – Part II
[Continued from Customer Identification Program (CIP): Definitions and Requirements – Part I] How Does Risk Assessment Affect a Firm’s CIP? Appropriate verification procedures for a CIP are governed by a risk-based assessment. A CIP must include risk-based procedures for verifying the identity of each customer to a reasonable and practicable [...]
Customer Identification Program (CIP): Definitions and Requirements – Part I
Customer Identification Program A broker-dealer must establish, document, and maintain a written Customer Identification Program (CIP) as a part of the broker-dealer’s anti-money laundering (AML) compliance program (31 CFR 1023.220) as required by FINRA Rule 3310. The CIP must be appropriate for the broker-dealer’s size and business, and it must [...]
RegTech: Regulatory Intelligence & Risk Management and Assessment
This blog post is the third and final entry in our series on the five major areas of Regulatory Technology (RegTech) tools as determined by FINRA: surveillance and monitoring, customer identification and anti-money laundering (AML) compliance, regulatory intelligence, reporting and risk management, and investor risk assessment. If you missed our [...]