Communication Recordkeeping in the Day of the Hybrid Workforce

Communication Recordkeeping in the Day of the Hybrid Workforce

All broker dealers have recordkeeping obligations required by Rule 17a-4(b)(4) under the Securities Exchange Act of 1934. Among the list of required obligations is communication recordkeeping. This includes incoming as well as outgoing communications with respect to the broker dealer. Further instructions were given by the Financial Industry Regulatory Authority (“FINRA”) in FINRA 11-39 and later in FINRA 17-18. This is noted because over the course of the past years, the hybrid work environment has become the norm. With this, more and more communication software and applications have become available to the public to ease the transition between working from Read more about Communication Recordkeeping in the Day of the Hybrid Workforce[…]

Code of Ethics

Code of Ethics Concerns During COVID-19 and Beyond

COVID-19 has bought a “new normal”. From stay-at-home orders and teleworking requirements to market volatility, consumer worry, and delayed public disclosure, the face of the industry will be forever changed. In light of this, Registered Investment Advisor compliance departments should consider reviewing the landscape of the Code of Ethics requirements.

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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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FINRA Requests Comment on Rules Governing Communications with the Public

FINRA recently published a Regulatory Notice to announce that it is currently soliciting comment on proposed amendments to FINRA Rule 2210 (Communications with the Public). Rule 2210 provides that communications may not predict or project performance, imply that past performance will recur or make any exaggerated or unwarranted claim, opinion or forecast.

  The general prohibition against performance projections is largely intended to protect retail investors from performance projections of individual investments, which often prove to be spurious, inaccurate or otherwise misleading. Read More…

Utilization of Social Media in the Securities Industry

In today’s culture, the utilization of social media for business purposes is becoming more and more commonplace and regular.  You look at a Linked-In profile before scheduling someone for an interview.  You follow FINRA and the SEC on Twitter and you review the Facebook page of Michael Bloomberg.  Securities firms and their representatives are taking their business to social media, as well.  However, before doing so, there are some important ramifications and requirements to consider. Read More…

FINRA Rule 2210: Communications

As should be expected, broker dealers are not free to communicate with the public, including retail and institutional investors, without restrictions.  The regulation of communications with the public minimizes, although it does not eliminate, the chance that the public will be misled by a firm’s advertisements.  FINRA Rule 2210 establishes the standards for the content, approval, recordkeeping, and filing of communications with FINRA. Read More…