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.
Beginning in 2017, the United States Security and Exchange Commission (“SEC”) initiated a series of examinations aimed at compliance policies and procedures regarding individuals within these firms that had a prior disciplinary history.
If you are a broker dealer or a supervisor at a broker dealer, I’m sure you have come across the terms Written Supervisory Procedures, Supervisory Procedures, and Compliance Systems. How many of you really know the difference, and before your eyes glaze over the rest of the article, how many of you know how to properly execute these concepts…. I’ll wait…….
Great! Now that I have your attention, there is no need to panic. The following post will walk you through the differences, some key concepts, practice pointers, and other factors you need to be aware of.
FINRA warns member firms to be on the lookout for a fraudulent phishing emails that are currently circulating. Recently, member firms have reported to FINRA that they have received suspicious emails targeting their compliance personnel.
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[Continued from Regulation Crowdfunding – Part I]
Crowdfunding Requirements for Intermediaries
The following requirements apply to both broker-dealers and funding portals acting as an intermediary in a transaction involving the sales of securities pursuant to Regulation Crowdfunding (“Regulation CF”):
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- Register with the SEC as a broker or as a funding portal.
- Register with a self-regulatory organization (“SRO”); the only eligible SRO at present being FINRA.
Annual broker-dealer training should be derived from relevant regulatory and/or industry focus areas. It is important to consider the current “hot topics” and implement appropriate training regarding the areas that would best mitigate risk when performing needs analysis and developing an annual broker-dealer training plan. Read More…