Firms should have appropriately established controls for review, approval, and archiving of all firm related websites and related content. Firms must be able to readily produce all current and historical website content that promotes the firm or any of its covered persons. The firm should establish controls to ensure that all content is approved prior to use by a designated supervisor. Such supervisor is to have appropriate knowledge related to such content requirements. The guidelines below do not represent an exclusive list of considerations that a supervisor must make in determining whether such website complies with all applicable standards. Content Read more about Website Reviews[…]
SEC Rule 204-2 require that firms make and keep required books and records for prescribed periods, and furnish copies of such records as necessary. Examples of such records include, but are not limited to electronic communication, advertisements, trade blotters, asset and liability ledgers, income ledgers, customer account ledgers, securities records, order tickets, trade confirmations, trial balances, and communications that relate to the firm’s business. Any records that are considered to be “original records” are required to be archived appropriately. Firms that elect to use electronic storage to maintain such records may only do so if they establish policies and procedures to:
- Safeguard the records from loss, alteration, or destruction;
- Limit access to the records to authorized personnel and regulators; and
- Ensure that electronic copies of non-electronic originals are complete, true, and legible.
As a registered adviser, you must make and keep true, accurate and current certain books and records relating to your investment advisory business. Federal covered advisers registered under section 203 of the Act (15 U.S.C. 80b-3) are required by the SEC to make and keep true, accurate and current books and records relating to its investment advisory business of the following:
You get that call, and your heart drops. You knew that a regulatory exam was on the horizon, but you have put off thinking about it. Now, you are face-to-face with an upcoming FINRA examination, and the panic has set in.
Your firm is beginning to get in the groove since the shelter-in-place orders have been implemented. In the past, you have worked from home on certain days, but the transition to full-time teleworking, homeschooling, and pet sitting has been a challenging reality. Then surprise! You get a call from your regulatory coordinator that FINRA or the SEC has decided to conduct a regulatory exam of your firm starting now.
Is your small broker-dealer drowning in boxes and boxes of paper? Do you cringe every time you think of storing yet another 50+ page document? Are you interested in exploring the benefits of cloud-based storage? If you answered “yes” to any of these questions, you must first consider your firm’s regulatory requirements for electronic storage media.