Ethical Considerations for FINOP’s

Ethical Considerations for FINOP’s

Ethical Considerations for FINOP’s In the financial services industry, the Financial and Operations Principal (“FINOP”) plays a critical role in establishing and maintaining the integrity and efficiency of a broker dealer. Because of this, the FINOP has a significant ethical obligation that must be carefully navigated to ensure that fairness, integrity, and lawful practices are at the forefront of their position. Below are several key considerations for Financial and Operations Principals (“FINOPS”) to implement as part of their best practices with their broker dealer firms. Accuracy and Integrity of Financial Reporting – FINOPS are responsible for certifying accurate and transparent Read more about Ethical Considerations for FINOP’s[…]

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[…]

FINRA’s Top Priorities for 2022

FINRA’s Top Priorities for 2022

Early in the year, FINRA released their 2022 Report on FINRA’s Examination and Risk Monitoring Program, which is designed to inform member firms’ compliance programs by providing annual insights from FINRA’s ongoing regulatory operations. In this report detailing FINRA’s top priorities for 2022, FINRA addresses 21 regulatory areas which are grouped into 4 categories: (1) Firm Operations, (2) Communications and Sales, (3) Market Integrity, and (4) Financial Management. From these 21 regulatory areas, FINRA highlights 7 that they feel are the most important and affect a large portion of member firms, which are as follows: Reg BI and Form CRS Read more about FINRA’s Top Priorities for 2022[…]

Code of Ethics for Registered Investment Advisers

Code of Ethics for Registered Investment Advisers

All advisers registered with the SEC must adopt and enforce a written code of ethics reflecting the adviser’s fiduciary duties to its clients. The firm’s code of ethics is required to meet minimum standards to appropriately address conflicts of interest identified by the firm. To ensure compliance with the code of ethics requirements, a written acknowledgement should be obtained from each supervised person confirming receipt of the firm’s code of ethics. Firms with more than one access person are should also ensure transaction reporting is being done by all access persons.

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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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