Supervision

Supervision Relief Related to COVID-19 Pandemic

FINRA Rule 3110 Supervision requires a firm to establish and maintain a system to supervise the activities of its associated persons. Furthermore, the supervisory process seeks to achieve compliance with the applicable securities laws and regulations and FINRA rules.

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Compliance

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.

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Teleworking

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.

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BCP

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.

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Examinations and Risk Monitoring

Examination and Risk Monitoring: What to Expect in 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…

Annual Compliance Meeting

Annual Compliance Meeting: A Retrospective Review

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 19-34Although 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.

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FINRA Disciplinary Actions

FINRA Disciplinary Actions from January 2020

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.

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annual training

Annual Training Considerations for Broker/Dealers

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…