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.
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.
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.
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.
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.
FINRA recently released a podcast called “What to Expect: The 2020 Exam and Risk Monitoring Program“. It provides a wealth of information from three members of the Member Supervision Senior Leadership on what to expect from the Examination and Risk Monitoring program in 2020. Here are a few highlights from the podcast. Read More…
FINRA initiated a retrospective review of the annual compliance meeting (“ACM”) requirement in April 2018. The findings were published on October 18, 2019 in FINRA Regulatory Notice 19-34. Although the final assessment indicates that they are determined to maintain the ACM requirement without change, the Notice did provide additional guidance on fulfilling the requirements.
The Monthly Disciplinary and Other FINRA Actions report from January may provide a glimpse into the conduct by Firms and individuals that result in disciplinary proceedings. For Firms, a failure to evolve a program can be costly. For individuals, failure to disclose despite Firm-acknowledged requests may result in FINRA sanctions.
It’s 2020 and as the new year rolls in, so does annual training planning. Rule 3110(a)(7) requires each Registered Person to participate, at least annually, in an interview or meeting which discusses compliance matters relevant to their activities. Read More…