It has been an exciting year for Securities Compliance Management (“SCM”)

The Ultimate Solution for Compliance Management

It has been an exciting year for Securities Compliance Management (“SCM”). The Firm has successfully: Initiated numerous New Membership Applications (“NMAs”) for new firms seeking the Financial Industry Regulatory Authority’s (“FINRA”) approval, Initiated several Continuous Membership Applications (“CMAs”) for existing firms that are planning to undergo a material change in their line of business operations, Partnered with new broker-dealer and registered investment advisor firms to assist them with their FinOp and/or compliance programs, and Assisted in the buy/sell of existing broker-dealer firms. Along with the new relationships that Securities Compliance Management has established this year, the Firm is also incredibly Read more about The Ultimate Solution for Compliance Management[…]

Form CRS Observations

Form CRS Observations

Broker dealers, specifically the Chief Compliance Officer (“CCO”), are required to review their firm’s compliance programs and procedures at least annually to ensure that all compliance areas are working in accordance with the rules and regulations set forth by the Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”). Per the Securities Exchange Act of 1934 under rule 17a-14, one area of review for broker dealers who maintain retail clients is Form CRS, the customer relationship summary. Form CRS contains various information regarding the broker dealer that is important for retail clients to know. Over the past Read more about Form CRS Observations[…]

Three Main Focal Points of Newly Registered Firms

Exam Observations for New Firms

In March 2023, the Securities and Exchange Commission (“SEC”) released an alert article with some observations that they have seen when examining newly registered firms. Note that these alerts are not rules or regulations of any regulatory authority. However, investment advisory firms and broker dealers can garner many important takeaways that may assist the firm during an examination. It is important for any new firm – whether broker dealer or registered investment advisor – to start communicating and engaging with its regulatory contacts. Having an open line of communication can provide value to investment advisors and/or broker dealers in building Read more about Exam Observations for New Firms[…]

The role of a Chief Compliance Officer

The Chief Compliance Officer

As with all career choices, there are some vital pieces of information that are not included in the textbooks. Being a Chief Compliance Officer (“CCO”) is no exception to this rule. There are simply aspects of the position where life experience becomes the CCO’s guidebook. A thorough Chief Compliance Officer within a broker dealer (“BD”) is not every employee’s favorite person. Holding all employees to the strict processes and procedures set forth for the broker dealer can sometimes feel like a full-time job in itself. Being a CCO can be a thankless position, but the rewards can also be great. Read more about The Chief Compliance Officer[…]

Outsourced Compliance for Broker Dealers

Outsourced Compliance

Are there times when as a Financial Industry Regulatory Authority (“FINRA”) approved and registered broker dealer that you feel your broker dealer is lost in an ocean of overwhelming rules and regulations? You may feel as though your firm is drowning in a plethora of obligations and tasks. It is times like this when broker dealers can find drastic benefits of outsourcing some of its compliance functions. Having outside compliance is not a requirement of FINRA, but it is understandable given the constant stream of changes in the world of the broker dealer industry. There is a level of comfort Read more about Outsourced Compliance[…]

PTE and IRA Rollover Recommendation Considerations

PTE and IRA Rollover Recommendation Considerations

U.S. Department of Labor’s (“DOL”) recently published final prohibited transaction exemption regarding investment advice for IRA and ERISA plans (PTE 2020-02). This exemption became effective on February 16, 2021 allowing for a transition period to comply. Key elements include, written acknowledgments of fiduciary status by both the broker-dealer and the representative, disclosure of conflicts of interest and compensation information, the implementation of policies and procedures to mitigate or eliminate conflicts, as well as an annual reporting and certification of compliance. PTE’s conditions related to rollover recommendations went into effect on July 1st 2022. As we have worked with clients on Read more about PTE and IRA Rollover Recommendation Considerations[…]